Rasquin v. Humphreys

Decision in this case turns on the question, differing only in form from that this day decided in Sanford v. Helvering, ante, p. 39, whether, in case of an inter vivos transfer of property in trust, reserving to the donor power to designate new beneficiaries other than himself, the gift becomes complete at the time of the creation of the trust and subject to the gift tax imposed by the Revenue Act of 1932.

In December, 1934, respondent created a trust of personal property for his own benefit for life, with remainders over to specified classes of beneficiaries. By the •trust indenture he…