Stockstrom v. Commissioner of Internal Revenue

WILBUR K. MILLER, Circuit Judge.

The Revenue Act of 1932 provided with respect to gift taxes an exemption or “exclusion” of $5,000 in the case of gifts other than of future interests in property. A gift tax return was not required of a donor whose gift fell within that exemption.1

On January 6, 1936, Louis Stockstrom established ten irrevocable trusts and made a gift of less than $5,000 to each; but, as the Commissioner of Internal Revenue was then ruling that gifts to trusts were gifts of future interests not entitled to the statutory exclusion, Stockstrom filed gift tax returns covering his…