Does a provision in the Civil Code of Civil Procedure apply to gift tax cases?

MultiRegion, United States of America

The following excerpt is from Rickenberg v. Commissioner of Internal Revenue, 177 F.2d 114 (9th Cir. 1949):

3 Regulations 108, 86.2, making a similar provision in gift tax cases was held invalid as unwarranted by statute, 26 U. S.C.A. 1000(d), in Mills v. Commissioner, 12 T.C. 468.

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