CERF v. COMMISSIONER OF INTERNAL REVENUE

No. 8495.

141 F.2d 564 (1944)

CERF v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided March 10, 1944.


Attorney(s) appearing for the Case

Ewing Everett, of New York City, (Malcolm Johnson, of New York City, and Miller & Chevalier, of Washington, D. C., on the brief), for petitioner.

I. Henry Kutz, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Warren F. Wattles, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before MARIS, GOODRICH, and McLAUGHLIN, Circuit Judges.


GOODRICH, Circuit Judge.

The taxpayer in this litigation is Camelia I. H. Cerf. She petitions this Court for review of a decision of the Tax Court sustaining the Commissioner's determination of a gift tax deficiency against her for 1932. The significant events leading up to the present controversy begin some years prior thereto.

In 1928 Louis A. Cerf created four trusts. Each trust was for the benefit of his wife, Camelia I. H. Cerf, and one of their four...

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