District Court, W.D. Pennsylvania October 8, 1968, Civ. A. No. 68-152 (Miskovsky v. 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.