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GOLDSCHMIDT-ROTHSCHILD v. COMMISSIONER

Docket No. 7700.

9 T.C. 325 (1947)

MARIE-ANNE DE GOLDSCHMIDT-ROTHSCHILD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 12, 1947.

Attorney(s) appearing for the Case

Maurice Austin, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

The respondent has determined a deficiency of $20,467.51 in the petitioner's gift tax liability for the calendar year 1941, all of which is in controversy.

Petitioner assigns error in the respondent's determination (1) that she was a resident of the United States at the time the gifts involved herein were made; (2) that the gifts, of the aggregate value of $189,465.30, did not constitute bonds, notes, or certificates of indebtedness...

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