United States Tax Court November 14, 1946, Docket No. 7921 (Lockard v. Commissioner)

lead-opinion

OPINION.

ARundell, Judge:

Initially, the controversy here is whether for gift tax purposes the transfers in trust in 1938 and 1939 were completed gifts, in view of the fact that the income of the trust for the years 1938 to 1941, inclusive, has been taxed to the petitioner as grantor under section 22 (a) of the Internal Revenue Code and the rule of Helvering v. Clifford, 309 U. S.