Court of Appeals for the Eighth Circuit May 9, 1973, 72-1579, 72-1580 (Lera H. Stark v. United States of America, William P. Stark v. United States)

PER CURIAM.

We are presented with the question whether, in order to claim the $3,000 gift tax exclusion pursuant to 26 U.S.C. § 2503(b), a taxpayer might satisfy his burden of proving that an income interest in a trust has “ascertainable value,”

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by reference to the actuarial tables found in Treas.Reg., 26 CFR § 25.2512-5 (c).