Smith v. Commissioner of Internal Revenue

RIDDICK, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals, the single question presented being whether certain transfers in trust made by the petitioner for the benefit of her four minor grandchildren were gifts of present or future interests under § 504(b) of the Revenue Act of 1932, 47 Stat. 247, 26 U. S.C.A. Int.Rev.Acts page 585. The petitioner contends that in computing her 1937 gift tax, she is entitled under the Act mentioned to a $5,000 exclusion as to the gift to each of the four beneficiaries of two trusts created by her on April…