# Heringer v. Commissioner > United States Tax Court · January 26, 1954 · 21 T.C. 607 URL: https://www.frixlaw.com/law-library/cases/4476626 ## Case - **Full name:** Stephen F. Heringer, 1 v. Commissioner of Internal Revenue - **Court:** United States Tax Court - **Decided:** January 26, 1954 - **Citations:** 21 T.C. 607; 1954 U.S. Tax Ct. LEXIS 308 - **Precedential status:** Published - **Opinion:** Dissent by Fossan - **Judges:** Fossan, Opper - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4476626 ## Opinion text 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. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4476626. Public record. Not legal advice.