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PAOLOZZI v. COMMISSIONER

Docket No. 46543.

23 T.C. 182 (1954)

ALICE SPAULDING PAOLOZZI, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 29, 1954.

Attorney(s) appearing for the Case

Philip B. Buzzell, Esq., for the petitioner.

Joseph Landis, Esq., for the respondent.

Respondent determined a deficiency in gift tax of petitioner for the calendar year 1938 in the amount of $24,511.97.

The only question presented is whether petitioner is taxable on the entire value of property transferred by her in trust, or whether she retained a life interest necessary to support a deduction therefor.

FINDINGS OF FACT.

The stipulation of facts filed by the parties with exhibits attached...

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