Union Planters National Bank, of the Estate of Forrest C. Ladd v. United States

HARRY PHILLIPS, Circuit Judge.

The single question presented on this appeal is this: When a husband conveyed his family residence to his wife as a completed gift without reserving any legal title, right or interest therein, but thereafter continued to live with his wife in the home until his death, is the value of the residence includible in his taxable estate for federal estate tax purposes ?

The district court answered this question in the negative.

This suit was filed to recover estate taxes paid by the executor of the estate of Forrest C. Ladd. Claim for refund was filed and rejected. The…