Legal Opinion
Lera H. Stark v. United States of America, William P. Stark v. United States
Court of Appeals for the Eighth Circuit
Decided May 9, 1973No. 72-1579, 72-1580PublishedCited by 16 opinions
1Per curiam
We are presented with the question whether, in order to claim the $3,000 gift tax exclusion pursuant to 26 U.S.C. § 2503(b), a taxpayer might satisfy his burden of proving that an income interest in a trust has “ascertainable value,” 1 by reference to the actuarial tables found in Treas.Reg., 26 CFR § 25.2512-5 (c).
The taxpayers made gifts of the stock of a closely held corporation to three trusts, for the benefit of each of the taxpayers’ three minor grandchildren. The beneficiaries were to receive the net income from the trusts until each reached the age of 30, at which time the…
2Cases cited8 opinions
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- Morgan v. CommissionerUnited States Tax Court · 1964
- Marvin R. Ray v. United StatesCourt of Appeals for the Fifth Circuit · 1956
- Pettus v. CommissionerUnited States Tax Court · 1970
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Fred A. Berzon v. Commissioner of Internal Revenue, Gertrude Berzon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Berzon v. CommissionerUnited States Tax Court · 1975
- Estate of Gribauskas v. CommissionerUnited States Tax Court · 2001
- Calder v. CommissionerUnited States Tax Court · 1985
- Alma M. O'Reilly v. Commissioner of Internal Revenue, Charles H. O'reilly, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
11 more not listed; retrieve them via the Exa API.