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POPE v. COMMISSIONER

Docket No. 33857.

12 T.C.M. 646 (1953)

William H. Pope v. Commissioner.

United States Tax Court.

Entered June 8, 1953.

Attorney(s) appearing for the Case

Richard V. Zug, Esq., for the petitioner. Edward Pesin, Esq., for the respondent.

Memorandum Opinion

LEMIRE, Judge:

Respondent determined a deficiency of $465 in gift tax for 1947. The sole issue is whether gifts made by petitioner in trust for the benefit of his two minor children were gifts of present interests so as to entitle petitioner to the statutory exclusions provided in section 1003 (b) (3) of the Internal Revenue Code.1

All of the facts have been...

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