Exchange Bank & Trust Co. v. United States

BENNETT, Circuit Judge.

This appeal from a final judgment of the United States Claims Court, entered October 8, 1982, which denied the refund of estate taxes, presents an issue of first impression: whether the “reciprocal trust” doctrine should be applied to a series of simultaneous transfers of property by a husband and wife to their children under the Florida Gifts to Minors Act, where each spouse appoints the other spouse as guardian. The United States Claims Court, in an as yet unpublished opinion by Judge Wiese,1 applied the reciprocal trust doctrine to “uncross” the transfers, and…