PATTERSON, District Judge.
The action is one at law to recover taxes paid under the Gift Tax Act of 1932. The Act (26 U.S.C.A. § 550) imposes a tax on transfers of property by gift in the year 1932 and later years, but not on transfers by gift made on or before the enactment of the Act, June 6, 1932. The plaintiff moves for judgment on the pleadings under rule 112 of the New York Rules of Civil Practice.
The case shown by the complaint is this: Helen...
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