D. Clifford Crummey v. Commissioner of Internal Revenue

This case involves cross petitions for review of decisions of the Tax Court of the United States. Jurisdiction in the Tax Court was based upon 26 U.S.C. § 7442 . Jurisdiction in this court is based upon 26 U.S.C. §§ 7482 and 7483.

On February 12, 1962, the petitioners executed, as grantors, an irrevocable living trust for the benefit of their four children. The beneficiaries and their ages at relevant times are as follows:

John Knowles Crummey

Janet Sheldon Crummey

David Clarke Crummey

Mark Clifford Crummey

Age 12/31/62 12/31/

22

20

15

11

Originally the sum of $50 was contributed to the trust. Thereafter, additional contributions were made by each of the petitioners in the follow-

Central District of California, sitting by desig ing amounts dates: and on the following

$ 4,267.

49,550.

12,797.

6/20/

J ' 12/19/

The dispute years of 1962 revolves around the tax and 1963. Each of the petitioners filed a gift tax return for each year. Each petitioner claimed a $3,000 per beneficiary tax exclusion un(jer provisions 0f 26 U.S.C. § 2503 (b). The total claimed exclusions were as fol- , lows :

D. C. Crummey

1962 — $12,000

1963 — $12,000

E. E.…