Blaffer v. Commissioner

McCORD, Circuit Judge.

The Petition for Review involves gift tax deficiency determinations for the calendar years 1936 and 1937 in the respective amounts of $8,837.67 and $5,024.75.

During the years 1936 and 1937, R. L. Blaffer made substantial gifts of property to certain of his children and to certain trusts for their use and benefit. In his gift tax return he claimed an exclusion of $5,000 in respect to each of the gifts made to trusts. The multiple exclusions were claimed on the theory that within the meaning of Section 504(b) of the Revenue Act of 1932, 26 U.S.C.A. Int.Rev.Acts, page 585…