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BERZON v. C. I. R.

Nos. 860, 861, Dockets 75-4197, 75-4198.

534 F.2d 528 (1976)

Fred A. BERZON, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Gertrude BERZON, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided April 27, 1976.

Attorney(s) appearing for the Case

Leonard L. Silverstein, Washington, D. C. (Robert E. Falb, Silverstein & Mullens, Washington, D. C., and Murray Roth, New York City, on the brief), for appellants.

Stanley S. Shaw, Jr., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews and Grant W. Wiprud, Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before KAUFMAN, Chief Judge, and SMITH and ANDERSON, Circuit Judges.

ROBERT P. ANDERSON, Circuit Judge:

These are appeals from decisions of the United States Tax Court, holding that certain inter vivos gifts made, in trust, by the appellants, Fred A. Berzon and Gertrude Berzon,1 failed to qualify for the $3,000 annual gift tax exclusion under Title 26 U.S.C. § 2503(b) of the Internal Revenue Code, and determining gift tax deficiencies of $19,276.05 for each appellant. The gifts at issue involve a total...

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