Legal Opinion

Duffey v. United States

District Court, D. Minnesota

Decided February 17, 1960No. 4-59 Civ. 10, 11PublishedCited by 1 opinion

1Opinion of the Court

NORDBYE, District Judge.

The taxpayers, Clement J. Duffey and his wife, have each brought an action against the Government to recover federal gift taxes paid pursuant to deficiency assessments for the year 1954. These actions arise out of the Commissioner’s treating the interests of certain beneficiaries under trusts established by one of the taxpayers as being future interests and not subject to the $3,000 annual gift tax exclusion permitted by 26 U.S.C. § 1003(b)(3), Internal Revenue Code of 1939.

It is undisputed that on December 30, 1954, Clement J. Duffey transferred stock to certain…

2Cases cited7 opinions

  1. United States v. PelzerSupreme Court of the United States · 1941
  2. Fondren v. CommissionerSupreme Court of the United States · 1945
  3. Commissioner v. DisstonSupreme Court of the United States · 1945
  4. Ryerson v. United StatesSupreme Court of the United States · 1941
  5. French v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943

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3Cited by1 opinion

  1. Swigert v. StraubCourt of Appeals of Oregon · 1972

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