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MISKOVSKY v. UNITED STATES

Civ. A. No. 68-152.

290 F.Supp. 403 (1968)

Frank MISKOVSKY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court W. D. Pennsylvania.

October 8, 1968.

Attorney(s) appearing for the Case

Robert G. MacAlister, Pittsburgh, Pa., for plaintiff.

Gustave Diamond, U. S. Atty., Pittsburgh, Pa., for United States.

OPINION

DUMBAULD, District Judge.

Although accountants or economists may find it unsound, Congress for the sake of convenience has established a system of annual determination1 of tax liability for income and gift taxes. That the gift tax obligation for a particular year constitutes a single, unitary, and indivisible obligation is shown by 26 U.S.C. § 6019.

Therefore the unit rule prescribed for income tax liability...

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