Legal Opinion
Wells Fargo Bank v. Cory
California Court of Appeal
Decided September 16, 1980No. Civ. 48378PublishedCited by 3 opinions
1Opinion of the Court
Opinion
FEINBERG, J.
On May 5, 1969, in consideration for a $725,876.49 promissory note, payable on demand at no rate of interest, Ruth H. Lilienthal made loans and advances of $725,656.49 to her son, Phillip N. Lilienthal III. Some partial payments were made, but in 1973, Mrs. Lilienthal forgave $300,000 of the outstanding balance and filed a gift tax return. When the mother died in 1975, the balance due on the loan was $385,756.49.
On May 19, 1977, appellant Kenneth Cory, Controller of the State of California, determined that a gift tax was due for each of the various periods during which the…
2Cases cited12 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Palos Verdes Faculty Ass'n v. Palos Verdes Peninsula Unified School DistrictCalifornia Supreme Court · 1978
- Edison California Stores, Inc. v. McColganCalifornia Supreme Court · 1947
- Lester Crown v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978
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3Cited by3 opinions
- Armstrong v. County of San MateoCalifornia Court of Appeal · 1983
- Dreyer's Grand Ice Cream, Inc. v. County of AlamedaCalifornia Court of Appeal · 1986
- Armstrong v. County of San MateoCalifornia Court of Appeal · 1983