Commissioner of Internal Revenue v. Krebs

THOMPSON, Circuit Judge.

These are petitions for review of two decisions of the Board of Tax Appeals. In , 1932 the taxpayer created three irrevocable trusts for the benefit of each of his three children. He transferred to each of those trusts without any valuable consideration, $5,000. In 1933, without any valuable consideration, he transferred to each of the trusts 50 shares of Dupont Company stock of the value of $4,712.50 and cash in the following amounts: $656.37, $667.88, and $658.25. In the same year he created three additional irrevocable trusts with the same beneficiaries and…