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PHILLIPS v. COMMISSIONER

Docket Nos. 17794, 19081.

12 T.C. 216 (1949)

JESSE S. PHILLIPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 21, 1949.

Attorney(s) appearing for the Case

Thomas H. Bivin, Esq., for the petitioner.

Ellyne E. Strickland, Esq., for the respondent.

The Commissioner determined deficiencies in gift tax for 1944 and 1946 in the amounts of $1,258.21 and $2,469.76, respectively. The question to be determined is whether certain gifts made by petitioner in 1944 and 1946 under the trusts created by him in 1944 were transfers of future interests within the meaning of section 1003 (b) (3) of the Internal Revenue Code so that no exclusions, except as conceded by respondent, are allowable...

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