Legal Opinion

Willis v. United States

District Court, D. Maryland

Decided March 1, 1978No. Civ. T-76-379PublishedCited by 2 opinions

1Opinion of the Court

THOMSEN, Senior

District Judge.

In this action, tried before the court without a jury, Plaintiff seeks recovery of gift taxes for the years 1971 and 1972 and interest thereon, assessed against her and paid by her to the Government. Plaintiff contends: (1) that gifts in trust of an income interest, made by her in December 1971 and January 1972, constitute present interest qualifying for the $3,000 per donee exclusion under section 2503(b) of the 1954 Code; and (2) that the actuarial tables promulgated by the Internal Revenue Service in the Gift Tax Regulations are the appropriate method for…

2Cases cited3 opinions

  1. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  2. Commissioner v. DisstonSupreme Court of the United States · 1945
  3. Mercantile-Safe Deposit and Trust Co. v. United StatesDistrict Court, D. Maryland · 1970

3Cited by2 opinions

  1. Maryland National Bank and Ralph Norris, Personal Representatives of the Estate of Katherine L. N. Willis, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1980
  2. Maryland National Bank and Ralph Norris, Personal Representatives of the Estate of Katherine L. N. Willis, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1980

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