
    Boyd, by Guardian ad litem, and others, Respondents, vs. Department of Taxation, Appellant. [Two cases.]
    
      November 13
    
    December 8, 1942.
    
    For the appellant there was a brief by the Attorney General and Harold H. Persons, assistant attorney general, and oral argument by Mr. Persons and Mr. Neil Conway, inheritance tax counsel.
    For the respondents there was a brief by Lecher, Michael, Whyte & Spohn of Milwaukee, and oral argument by George D. Spohn.
    
   Rosenberry, C. J.

The question involved in these cases is whether the twenty-five per cent additional tax imposed by par. (e) of sub. (3) of sec. 4, ch. 363, Laws of 1933, is applicable to the entire value of gifts made during a calendar year or only to the portion not in excess of $25,000? These cases are ruled by the cases in which Clara A. Miller, donor, is respondent and the Wisconsin Department of Taxation is appellant, ante, p. 615, 6 N. W. (2d) 827. Reference is made to the opinion and discussion in those cases, and in accordance with that opinion, the judgment in each case is affirmed.

By the Court. — Judgment in each case is affirmed.  