Legal Opinion
Carpenter v. United States
United States Court of Claims
Decided March 14, 1984No. 691-81TPublishedCited by 9 opinions
1Opinion of the Court
OPINION
LYDON, Judge:
In 1970, plaintiff1 executed a trust document wherein he transferred to a trust his remainder interest in his mother’s 1927 trust. The Internal Revenue Service (IRS) assessed a gift tax on this transfer on the ground that plaintiff’s execution of the *708trust document constituted a gift to the 1970 trust of his remainder interest under I.R.C. § 2501(a)(1) (Supp. V 1969). Plaintiff paid the tax assessment and sues here for a refund of $142,979.25, plus interest.
Plaintiff maintains that his execution of the trust instrument did not constitute a gift of his remainder interest…
2Cases cited47 opinions
- First Nat. Bank of Ariz. v. Cities Service Co.Supreme Court of the United States · 1968
- Upton v. TribilcockSupreme Court of the United States · 1875
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Zweig v. Hearst Corp.Court of Appeals for the Ninth Circuit · 1975
- Yuba Goldfields, Inc. And Placer Service Corp. v. The United StatesCourt of Appeals for the Federal Circuit · 1983
42 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Nicholson v. United StatesUnited States Court of Federal Claims · 1993
- Lamirage, Inc. v. United StatesUnited States Court of Federal Claims · 1999
- Alaska American Lumber Co. v. United StatesUnited States Court of Claims · 1992
- Carpenter v. United StatesUnited States Court of Claims · 1985
- City of Gettysburg v. United StatesUnited States Court of Federal Claims · 2005
4 more not listed; retrieve them via the Exa API.