Herrmann v. Commissioner

OPINION.

Arundell, Judge:

In the instant case the sole question to be determined is whether- certain gifts in trust of an undivided community interest in a Texas oil and gas lease were completed in 1942 or 1943. Petitioner does not challenge the computation of the deficiency asserted by -the respondent, if it is held herein that 1943 was the year in which the gift was consummated. There is no apparent dispute about the facts or that Texas law will determine when the title was transferred. The parties do disagree, however, as to whether the facts occurring in 1942 were legally sufficient to…