(Download) "Commissioner of Internal Revenue v. Phillip S Estate" by United States Court of Appeals for the Fifth Circuit * eBook PDF Kindle ePub Free

eBook details

Title: Commissioner of Internal Revenue v. Phillip S Estate
Author : United States Court of Appeals for the Fifth Circuit
Release Date : January 20, 1942
Genre: Law,Books,Professional & Technical,
Pages : * pages
Size : 67 KB

Description

The petition for review involves gift tax for the year 1936. The facts were stipulated, and the sole question presented below was whether under 504(b) of the Revenue Act of 1932, 47 Stat. 169, 247, 26 U.S.C.A. Int. Rev. Acts, page 585, the donor of property in trust for the benefit of thirteen beneficiaries was entitled to a single gift tax exclusion of $5,000, or to thirteen separate exclusions not exceeding $5,000 each. The Board held that the beneficiaries were the donees of the gifts, and that in determining the donors gift tax liability he should be allowed an exclusion not exceeding $5,000 for each of them.