Cornelius A. Ross, and Effie H. Ross v. Commissioner of Internal Revenue

POOLE, Circuit Judge:

Appellants Cornelius Ross 1 and his surviving wife, Effie, seek review of the judgment of the United States Tax Court sustaining the Commissioner’s assessment of $21,084.28 in delinquent gift taxes against each of them. We affirm the judgment of the tax court sustaining the deficiencies.

I

In 1972, appellants transferred property to each of their ten minor grandchildren, employing three trust instruments containing substantially identical dispositive provisions. Each cestui que trust was given a power of appointment over his share of the trust fund, exercisable by will, in…