The opinion
On Petition for Rehearing and Reargument.
PER CURIAM.
The petition for rehearing presents no point that we have not already fully considered. At the time that taxpayer executed the deeds of gift to his wife and sons, the profit on his purchase of the interest in the law suit had already been rendered certain by the judgment of the Court of Claims and denial of certiorari by the Supreme Court. The effect of the deeds of gift, therefore, was to transfer interests in this certain profit as well as interests in the original investment upon which the profit was realized. We think that the profit had been realized with sufficient definiteness- at the time of the transfer to require that it be treated as income of the taxpayer and not of the transferees. The “equities” to which reference is made in the opinion have significance only to the extent that they show that the decision arrived at on the legal basis above indicated accords with what is reasonable and right in the premises. It was not intended to base the decision on fraud or bad faith, or to impute these to the taxpayer.
Petition denied.