United States v. Pelzer, 312 U.S. 399 (1941)

United States v. Pelzer


No. 393


Argued January 7, 1941
Decided March 3, 1941
312 U.S. 399

CERTIORARI TO THE COURT OF CLAIMS

Syllabus

1. Decided in part upon authority of Helvering v. Hutchings, ante, p. 393. P. 401.

2. The revenue laws are to be construed in the light of their general purpose to establish a nationwide scheme of taxation uniform in its application. Their provisions are not to be taken as subject to state control or limitation unless the language or necessary implication of the section involved makes its application dependent on state law. P. 402.

3. Gifts in trust to grandchildren, limited to those who survive a ten-year accumulation period and attain twenty-one years of age, are gifts of "future interests," from which the $5,000 exemption in computing gift taxes is withheld by § 504(b) of the Revenue Act of 1932. P. 403.

90 Ct.Cls. 614; 31 F.Supp. 770, reversed.

Certiorari, 311 U.S. 634, to review a judgment of the Court of Claims granting a recovery of money collected as gift taxes.