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NEWMAN v. COMMISSIONER

Docket No. 29650.

19 T.C. 708 (1953)

LOIS J. NEWMAN (FORMERLY LOIS J. SENDERMAN), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 22, 1953.

Attorney(s) appearing for the Case

Samuel Taylor, Esq., and Walter G. Schwartz, Esq., for the petitioner.

Edward H. Boyle, Esq., for the respondent.

This proceeding involves a deficiency in gift tax of petitioner for the year 1946 in the amount of $71,195.99.

The issues presented are: (1) Whether the transfer by petitioner in 1943 of certain property in trust constituted a completed gift in that year or whether, as determined by respondent, the completed gift occurred in 1946 upon termination of the trust and distribution of the corpus to the guardian for the beneficiary; and (2) whether such gift, if effected...

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