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HARDING v. COMMISSIONER

Docket No. 6098.

11 T.C. 1051 (1948)

WILLIAM BARCLAY HARDING, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 22, 1948.

Attorney(s) appearing for the Case

George R. Sherriff, Esq., and William G. McKnight, Jr., Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

The Commissioner has determined a deficiency of $47,879.94 in petitioner's gift tax for the year 1941. The deficiency results from the addition to the gifts reported in the return filed by petitioner of "Item 1 — Transfers to Constance Fox Harding in connection with separation agreement, $353,053.32." The Commissioner explained his action in the deficiency notice as follows:

It is held that the above transfers, made in 1941 to your wife, Constance Fox Harding...

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