Commissioner of Internal Revenue v. Beck's Estate

FRANK, Circuit Judge.

The Gift Tax Act of 1932, §§ 501(a) and (b) and 506, 26 U.S.C.A. Int.Rev.Acts, pages 580, 588, imposes a tax on “the transfer * * * of property by gift * * * whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible * * ; and provides that “if the gift is made in property, the value thereof at the date of the gift shall be considered the amount of the gift.” The Senate and House Reports relating to that Act stated: “The terms ‘property,’ ‘transfer,’ ‘gift,’ and ‘indirectly’…