Hughes v. Commissioner of Internal Revenue

HANEY, Circuit Judge.

This proceeding involves the taxability and extent thereof, of a gift by way of trust.

The taxpayer was, at the time of the creation of the trusts herein mentioned, a resident of California, and was 43 years old. The various parties interested in the trusts, with their ages at the time of creation of the trusts were as follows:

party age

Mother 73

Father 71

Taxpayer 43

Wife 29

First Daughter

On June 22, 1933, the taxpayer, by a trust instrument executed at Los Angeles, California, did “transfer, deliver and convey” certain securities having a market value of $55,600 to a bank in…