Sensenbrenner v. Commissioner of Internal Revenue

SPARKS, Circuit Judge.

This petition to review a decision of the United States Tax Court presents a new phase of the question of the taxability under § 504(b) of the Revenue Act of 1932, 26 U.S.C.A. Int.Rev.Code, § 1003(b), relating to gift taxes, of gifts in trust, the income of which is immediately payable to certain named beneficiaries, but the corpus of which is not to be delivered to them until termination of the trust. The Tax Court held that each gift, with respect to the income therefrom, was a gift of a present interest, and as to the principal, a future interest, within the .meaning…