Document Type
Article
Publication Title
Vanderbilt Law Review
Publication Date
1979
ISSN
0042-2533
Page Number
641
Keywords
nontaxability transfers, tax exemptions, gifts, Internal Revenue Code
Disciplines
Law | Taxation-Federal Estate and Gift | Tax Law
Abstract
The complexity of detail that characterizes the Internal Revenue Code (Code) has been the subject of intense criticism and only faint praise. Yet, one of the more striking anomalies of the Code is that its often suffocating detail coexists with the sparest definitions of many key terms. The term "gift" is a prime example. Although its meaning plays an instrumental role in income and gift taxation, the Code nowhere defines the term. As a result, the task of fleshing out its meaning has largely fallen on the Treasury, through the issuance of regulations and rulings, and on the courts, which over the years have crafted a unique common law.
Recommended Citation
Jeffrey Schoenblum,
The Changing Meaning of "Gift": An Analysis of the Tax Court's Decision in "Carson v. Commissioner", 32 Vanderbilt Law Review. 641
(1979)
Available at: https://scholarship.law.vanderbilt.edu/faculty-publications/436