Phipps v. Commissioner
United States Board of Tax Appeals
1. Upon facts showing that petitioner acquiesced in, affirmed, and benefited from respondent's allowance of a specific exemption of $38,000 in computing gift tax liability for the year 1933, which exhausted the total specific exemption of $50,000 allowed by section 505(a)(1) of the Revenue Act of 1932, held, that petitioner is not entitled to a further specific exemption in 1935, and that he has exercised his option to exhaust the allowable specific exemption for gift tax…
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1. Upon facts showing that petitioner acquiesced in, affirmed, and benefited from respondent's allowance of a specific exemption of $38,000 in computing gift tax liability for the year 1933, which exhausted the total specific exemption of $50,000 allowed by section 505(a)(1) of the Revenue Act of 1932, held, that petitioner is not entitled to a further specific exemption in 1935, and that he has exercised his option to exhaust the allowable specific exemption for gift tax purposes in 1933. 2. Petitioner gave to 13 persons on the same day small blocks of preferred stock of the same corporation…
1Opinion of the Court
*1016OPINION.
HaReon :
Issue 1. — The first question relates to petitioner’s gift tax liability for the year 1935. The question is whether or not petitioner is entitled to a specific exemption deduction in 1935 under the provisions of section 505 (a) (1) of the Revenue Act of 1932.1 Petitioner claims a specific exemption deduction in the amount of $26,150 for the purpose of computing his gift tax liability for the year 1935. Respondent disallowed the claimed deduction because petitioner had' been allowed as specific exemption for preceding calendar years three? deductions aggregating $50,000. The…
2Cases cited2 opinions
- Adams Express Co. v. Ohio State AuditorSupreme Court of the United States · 1897
- United States v. New River Collieries Co.Supreme Court of the United States · 1923
3Cited by15 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Maytag v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- Rushton v. CommissionerUnited States Tax Court · 1973
- Blanchard v. United StatesDistrict Court, S.D. Iowa · 1968
- Cochran v. CommissionerUnited States Tax Court · 1948
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