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ESTATE OF GOULD v. COMMISSIONER

Docket No. 10402.

6 T.C.M. 775 (1947)

Estate of Frank M. Gould, deceased, Bank of New York, and Paul J. Longua, Executors, v. Commissioner.

United States Tax Court.

Entered June 30, 1947.

Attorney(s) appearing for the Case

John G. Jackson, Jr., Esq., for the petitioners. Clay C. Holmes, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

This proceeding involves a gift tax deficiency in the amount of $253,501.77 for the year 1944.

Two issues are raised:

(1) Whether any part of a lump-sum payment made by Frank M. Gould (hereinafter referred to as decedent) to his wife, pursuant to a separation agreement which was incorporated into a divorce decree, is taxable as a gift.

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