those which case of control the imposition the sift tax. In the United States to tax + Holden, Collector, part the 142, an of attempt was a gift made made on the in the same year 72 L. Bd, of the gift 206, tex law was enacted, ihe of the court held inelude such @ the ¢ould gift gift, not decision on the to to gifts apply rather than law umconstitutional, if The dissenting conceded required if is strikingly Act of preferred to bese their ground that the act should not be construed consummated gales made pricr we, of tax eases, which imposes own, except that, much more its to a tax not contend statute, in factor, upon imposition are SSR that Kenroy seems to us, the indic: ates than did not no instances, has made used or of on 6, , Court applicable has corporations, Supreme be case motive point surtaxes would it in the A case as This thet some date, gifts, should do the aware provisions 1962, srevent also definitely Bl, The controlling such June course, effective unconstitutional, to 1932 to act its apply our that before to like act the the construed tax notive that but gift in to taxed, the place Judges construed be to declare be Revenue the majority their Ae Ra has is the availed statute of stockholders. said ; that,