Baur v. Commissioner of Internal Revenue

JONES, Circuit Judge.

The questions raised by the pending petition for review are (1) whether the donee of a gift of untaxable amount is personally liable, to the extent of the value of the gift, for an unpaid tax on a gift to another donee made by the same donor in the same calendar year and (2) whether such liability, if it exists, may be enforced against the donee, as a transferee, after the statute of limitations has run against the donor’s liability,- in the absence of proof that the donor was insolvent or that the gratuitous transfers made the donor insolvent.

The questions relate to the…