Clark v. Commissioner
United States Tax Court
Held: 1. Gifts of Arthur W. Clark's principal interests in Clifford trusts to the income beneficiaries thereof were not gifts of future interests and therefore were eligible for the annual gift tax exclusion of $ 3,000 per donee provided by sec. 2503(b), I.R.C. 1954. 2. Petitioners' failure to prove Virginia Clark's consent to gift-splitting precludes half of Arthur W. Clark's 1964 gifts from being considered as having been made by her under the gift-splitting provisions of…
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Held: 1. Gifts of Arthur W. Clark's principal interests in Clifford trusts to the income beneficiaries thereof were not gifts of future interests and therefore were eligible for the annual gift tax exclusion of $ 3,000 per donee provided by sec. 2503(b), I.R.C. 1954. 2. Petitioners' failure to prove Virginia Clark's consent to gift-splitting precludes half of Arthur W. Clark's 1964 gifts from being considered as having been made by her under the gift-splitting provisions of sec. 2513, I.R.C. 1954. 3. Respondent is not barred by the statute of limitations or estopped from redetermining the…
1Opinion of the Court
Arthur W. Clark, Petitioner v. Commissioner of Internal Revenue, Respondent; Virginia Clark, Petitioner v. Commissioner of Internal Revenue, Respondent
Clark v. Commissioner
Docket Nos. 3253-73, 3296-73
United States Tax Court
65 T.C. 126; 1975 U.S. Tax Ct. LEXIS 46;
October 28, 1975, Filed
Decision will be entered under Rule 155 in docket No. 3253-73.
Decision will be entered for the petitioner in docket No. 3296-73.
Held: 1. Gifts of Arthur W. Clark's principal interests in Clifford trusts to the income beneficiaries thereof were not gifts of future interests and therefore were eligible for the…
2Cases cited34 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Helvering v. HutchingsSupreme Court of the United States · 1941
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