The opinion
Van FossaN, J., dissenting: Despite the statement in the opinion in Robert H. Scanlon, 42 B. T. A. 997, that it is distinguishable on its facts from Frank B. Thompson, 42 B. T. A. 121, I have never been able to perceive a valid distinction in principle between the two cases.
Accordingly, I cannot agree with the holding of the majority that the Thompson case governs here, and that the transfers were taxable to the donors as gifts, nor can I agree that each donor is entitled to but one exclusion.