Legal Opinion
Estate of Robert v. Schuler, Deceased Jay Schuler and Thomas Schuler, Co-Personal Representatives v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided March 7, 2002No. 01-2109PublishedCited by 8 opinions
1Opinion of the Court
RILEY, Circuit Judge.
During 1994 and 1995, the decedent, Robert Schuler, transferred stock in two family-owned businesses to members of his brother’s family. The Internal Revenue Service (IRS) determined the stock transfers were reciprocal cross-gifts and assessed a deficiency of $215,758 against the estate. The United States Tax Court 1 upheld the deficiencies. We affirm the tax court’s judgment.
I. BACKGROUND
A. Factual Summary
Two brothers, Robert Schuler (Robert) and George Schuler, Jr. (George), owned interests in two family operated companies — Minn-Kota Ag Products, Inc. (Minn-Kota) and…
2Cases cited6 opinions
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Fehrs v. United StatesUnited States Court of Claims · 1980
- Adaline v. Kincaid v. United StatesCourt of Appeals for the Fifth Circuit · 1982
- Larry L. Sather v. CIRCourt of Appeals for the Eighth Circuit · 2001
- Estate of Alton Bean, Deceased Gary A. Bean, Administrator Mable Bean v. Commissioner of Internal Revenue, Gary A. Bean Cynthia Bean v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2001
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- CDI Trust v. U.S. Electronics, Inc. (In Re Communication Dynamics, Inc.)United States Bankruptcy Court, D. Delaware · 2008
- Mark W. Senda and Michele Senda v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2006
- Estate of Melvin W. Ballantyne, Deceased, Jean S. Ballantyne, Independent Jean S. Ballantyne, Court. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2003
- Est. of M.Ballantyne v. CIRCourt of Appeals for the Eighth Circuit · 2003
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
3 more not listed; retrieve them via the Exa API.