Legal Opinion
Leo J. Polack v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided May 3, 2004No. 03-1295PublishedCited by 18 opinions
1Opinion of the Court
LOKEN, Chief Judge.
Leo Polack gave 1,040,000 shares of Zip Sort, Inc. nonvoting common stock to his children. On his 1992 gift tax return, he reported $520,000 in taxable gifts, relying on appraiser Gerald Gray’s opinion that the shares were worth $.50 each at the time of the gifts. The Commissioner of Internal Revenue valued the shares at $1.65 each and assessed a gift tax deficiency of $442,200. Polack paid the assessed tax and petitioned the United States Tax Court for a redetermination of the deficiency. At trial, the Commissioner did not contend that the stock was worth $1.65 per share,…
2Cases cited11 opinions
- Fehrs v. United StatesUnited States Court of Claims · 1980
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- The First National Bank of Kenosha, as Personal Representative of the Estate of Ethel M. Rudy v. United StatesCourt of Appeals for the First Circuit · 1985
- Julia A. STRONG, Appellant, v. MERCANTILE TRUST COMPANY, N.A., AppelleeCourt of Appeals for the Eighth Circuit · 1987
- Estate of Ray A. Ford, Deceased Jack F. Ford and Richard A. Ford, Personal Representatives v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1995
6 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
- Knudsen v. Comm'rUnited States Tax Court · 2008
- Trout Ranch, LLC v. CommissionerCourt of Appeals for the Tenth Circuit · 2012
- Webber v. CommissionerUnited States Tax Court · 2015
- Zarlengo v. Comm'rUnited States Tax Court · 2014
13 more not listed; retrieve them via the Exa API.