Legal Opinion

Norair v. Commissioner

United States Tax Court

Decided February 10, 1976No. Docket No. 4092-74Published

On her 1960 and 1961 gift tax returns petitioner reported one-half of the gifts made by her husband in those years, claiming a portion of her specific exemption as an offset against said gifts. Her husband died in 1961 and the entire amount of these gifts was included in his gross estate.

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On her 1960 and 1961 gift tax returns petitioner reported one-half of the gifts made by her husband in those years, claiming a portion of her specific exemption as an offset against said gifts. Her husband died in 1961 and the entire amount of these gifts was included in his gross estate. In 1970 petitioner made gifts of $ 77,111.58 and on her Federal gift tax return claimed a specific exemption of $ 30,000. Held, petitioner, by executing a consent under sec. 2513, is considered to be the donor of one-half of the gifts made by her husband for purposes of the gift tax provisions. Held,…

1Opinion of the Court

Anne E. Norair, Petitioner v. Commissioner of Internal Revenue, Respondent

Norair v. Commissioner

Docket No. 4092-74

United States Tax Court

65 T.C. 942; 1976 U.S. Tax Ct. LEXIS 161;

February 10, 1976, Filed

Decision will be entered for the respondent.

On her 1960 and 1961 gift tax returns petitioner reported one-half of the gifts made by her husband in those years, claiming a portion of her specific exemption as an offset against said gifts. Her husband died in 1961 and the entire amount of these gifts was included in his gross estate. In 1970 petitioner made gifts of $ 77,111.58 and on her Federal…

2Cases cited5 opinions

  1. Goldstone v. CommissionerUnited States Tax Court · 1975
  2. Rachel H. Ingalls v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1964
  3. Ingalls v. CommissionerUnited States Tax Court · 1963
  4. English v. United StatesDistrict Court, N.D. Florida · 1968
  5. Norair v. CommissionerUnited States Tax Court · 1976

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