Estate of Minnie Hale, Deceased, Robert v. Hale v. United States

LIVELY, Senior Circuit Judge.

This appeal concerns the timeliness of claims for refund of gift taxes that the government admits were overpaid. The district court found that under all the facts and circumstances the taxpayer filed a timely informal claim.

I

Acting under a general power of attorney, Minnie Hale transferred property of her husband, George Hale, to herself. She then transferred portions of the same property as gifts to her son, his wife, and her grandson. All transfers took place between September 18, 1970, and December 2, 1972, when Minnie Hale died. George Hale was declared…