Hamersley v. United States

GREEN, Judge.

This is a suit to recover a tax collected under the provisions of what is commonly known as the gift tax of the Revenue Act of 1932 (section 501 et seq. [26 U.S.C.A. § 550 et seq. and notes]). There is no dispute as to the facts, which are as follows :

Plaintiff, on December 31, 1934, made a gift of $2,400,000 in principal face amount of United States 3% per cent. Treasury bonds due August 1, 1941, with -interest coupons attached. The Commissioner of Internal Revenue required the plaintiff to make a gift tax return for 1934 and to pay the sum of $322,415 as a gift tax in…