Legal Opinion

William A. Cook and Gayle T. Cook v. Commissioner of the Internal Revenue Service

Court of Appeals for the Seventh Circuit

Decided October 22, 2001No. 01-1471PublishedCited by 15 opinions

1Opinion of the Court

FLAUM, Chief Judge.

William A. Cook and Gayle T. Cook challenge a determination by the Tax Court that the spousal interests created in their respective Grantor Retained Annuity Trusts are not “qualified interests” within the meaning of 26 U.S.C. § 2702, and are therefore not entitled to exemptions from gift tax liability. For the reasons stated herein, we affirm the decision of the Tax Court.

I. BACKGROUND

In 1963, William and Gayle Cook established a business in their home to market and manufacture medical devices used during minimally invasive surgical procedures. That business, now called…

2Cases cited3 opinions

  1. Mark A. Warsco, Trustee v. Preferred Technical GroupCourt of Appeals for the Seventh Circuit · 2001
  2. Walton v. CommissionerUnited States Tax Court · 2000
  3. Freeport Country Club v. The United States of AmericaCourt of Appeals for the Seventh Circuit · 1970

3Cited by15 opinions

  1. Guralnik v. Comm'rUnited States Tax Court · 2016
  2. United States v. BrownCourt of Appeals for the Tenth Circuit · 2003
  3. Patricia A. Schott, Stephen C. Schott v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
  4. United States v. BrownCourt of Appeals for the Tenth Circuit · 2003
  5. Estate of Focardi v. Comm'rUnited States Tax Court · 2006

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