De Goldschmidt-Rothschild v. Commissioner of Int. Rev.

AUGUSTUS N. HAND, Circuit Judge.

The question raised by this appeal is' whether the Commissioner of Internal Revenue and the Tax Court were justified in concluding that the subject-matter of a transfer by the taxpayer was not exempt from gift taxes under the provisions of Article 2 of Regulations 79 and Section 86.2 of Regulations 108 of the Bureau of Internal Revenue, which, under authority of 31 U.S.C.A. § 750, provide that a gift of a bond, note or certificate of indebtedness issued by the Federal Government prior to March 1, 1941, if made by a non-resident alien not engaged in business in…