Stuart L. Faber and Shirley E. Faber v. United States

The question before us is whether ten gifts of $64,536 each to trusts made for the benefit of the minor children of Stuart L. Faber and Shirley E. Faber, his wife, were entitled to the $3,000 annual exclusion provided in Section 2503(b) of the Internal Revenue Code of 1954, 26 U.S.C. § 2503(b). The Commissioner held that they were not, and assessed a total gift tax deficiency of $5,753.36 for the year 1960. Appellants paid the deficiency and sued in the United States District Court for the Southern District of Ohio for its recovery. The cause was tried to the District Judge, who sustained the…