DocketNumber: Docket Nos. 1246, 1247.
Citation Numbers: 3 T.C.M. 806, 1944 Tax Ct. Memo LEXIS 145
Filed Date: 8/7/1944
Status: Non-Precedential
Modified Date: 11/20/2020
Memorandum Opinion
OPPER, Judge: These consolidated proceedings, involving gift tax deficiencies for the years 1938 and 1941 of $470.32 and $221.99, respectively, were presented on a stipulation of facts and documentary exhibits, all of which are hereby found as facts accordingly.
The gift tax returns for the years in question were filed in the collection district of Michigan. They covered gifts of four trusts established by the petitioner donor, of which she became trustee. As such, and as transferee, she is also petitioner here.
The sole question is whether four exclusions of $5,000 each are allowable, or whether the gifts were of future interests, thus prohibiting the exclusions. In