Legal Opinion
Marc Alan Levin, Estate of Myrtle S. Levin Prince, Deceased v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided February 19, 1993No. 92-1306PublishedCited by 7 opinions
1Opinion of the Court
OPINION
MURNAGHAN, Circuit Judge:
Here we are called upon to consider the interplay of federal gift tax and the federal estate tax.
Myrtle Levin Prince, while herself living, made in 1984 gifts of Atlanta Project Notes worth $20,000, as well as gifts of other property which made the annual gift tax exclusion for each donee 1 unavailable with respect to the $20,000 gift. Nor was the spousal sharing of the gift 2 applicable.
At the time the 1984 gift tax return was filed, what authority there was, Haffner v. United States, 585 F.Supp. 354 (N.D.Ill. 1984), aff’d, 757 F.2d 920 (7th Cir.1985), held…
2Cases cited5 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- E. I. Dupont De Nemours & Co. v. DavisSupreme Court of the United States · 1924
- United States v. Wells Fargo BankSupreme Court of the United States · 1988
- Haffner v. United StatesDistrict Court, N.D. Illinois · 1984
- Charles C. Haffner III and the Northern Trust Company, as Executors of the Will of Charles C. Haffner, Jr., Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1985
3Cited by7 opinions
- John E. Lane, Iii, Estate of Beverly W. Powell v. United States of America, John E. Lane, Iii, Estate of Beverly W. Powell v. United StatesCourt of Appeals for the Fourth Circuit · 2002
- Estate of O'Neal v. United StatesDistrict Court, N.D. Alabama · 2000
- Estate of Robinson v. CommissionerUnited States Tax Court · 1993
- Carroll Evanson, as Co-Personal Representative of the Estate of Alfred Eide, Deceased v. United StatesCourt of Appeals for the Eighth Circuit · 1994
- Estate of Robinson v. CommissionerUnited States Tax Court · 1993
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