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GRISWOLD v. COMMISSIONER

Docket No. 2073.

3 T.C. 909 (1944)

JOHN A. GRISWOLD, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 18, 1944.

Attorney(s) appearing for the Case

Albert E. James, Esq., for the petitioner.

Thomas R. Charshee, Esq., for the respondent.

OPINION.

DISNEY, Judge:

This case involves gift tax for the year 1941. The Commissioner determined a deficiency of $8,324.15 because of applying the gift tax to the entire value of a gift of $125,125 instead of $59,479.82 as returned by the petitioner, who took the view that the latter figure represented the value of a life interest in the corpus of $125,125, and that only such life interest was the subject of the gift. The petitioner, by amendment...

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