Jacob W. Blasdel and Ruth Alice Blasdel v. Commissioner of Internal Revenue

This is an appeal from the United States Tax Court, 58 T.C. 1014. It involves a determination of whether certain interests conveyed from the appellants to the donees are “future interests” and therefore not entitled to the $3,000 annual gift tax exclusion. We affirm the decision below.

In 1967, appellants transferred 290 acres of farm land to the Edgewood Farm Trust and named themselves as beneficiaries. They then executed gift agreements transferring fractional shares of their interests in the trust to eighteen family members (their children, the children’s spouses, and their grandchildren).…