Beavers v. Commissioner

In 1943 petitioner and his wife transferred to their two children by deed of gift 12,138 acres of land in Knox County, Texas, which they owned in community. Petitioner reported one-half of the value of the property as his gift, and his wife reported the other one-half as hers. Under the authority of Sec. 1000(d) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 1000(d),1 the Commissioner assessed the whole value of the gift to petitioner. Appealing to the Tax Court, petitioner attacked as unconstitutional the section under which the Commissioner’s determination was made. That court,…