Commissioner of Internal Revenue v. McLean

HUTCHESON, Circuit Judge.

These are appeals from a decision and opinion 1 of the Board re-determining deficiencies in gift taxes for the years 1933 and 34, and awarding relief which, while giving the commissioner largely the best of it, fully satisfied neither taxpayer nor commissioner. Rejecting taxpayer’s contention that, as to both years, the transfers in trust, executed simultaneously by husband and wife, were made in consideration of each other and were therefore made for adequate and full consideration in money and monies worth, the Board found that the 1933 transfers were completed…