Legal Opinion
Metzger v. Commissioner of Internal Revenue Service
Court of Appeals for the Fourth Circuit
Decided September 1, 1994No. 93-2112PublishedCited by 3 opinions
1Opinion of the Court
Affirmed by published opinion. Judge WILLIAMS wrote the majority opinion, in which Judge PAYNE joined. Judge LUTTIG wrote a separate dissenting opinion.
OPINION
WILLIAMS, Circuit Judge:
This is an appeal by the Commissioner of Internal Revenue from a -decision of the United States Tax Court in favor of. the taxpayer, the estate of Albert F. Metzger. The issue presented is whether noncharitable gifts in the form of cheeks are complete for federal gift tax purposes at the time of the unconditional delivery and deposit of the checks, or when the checks were actually honored by the drawee' bank. The…
2Cases cited11 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- United States Trust Co. v. HelveringSupreme Court of the United States · 1939
- Spiegel v. CommissionerUnited States Tax Court · 1949
- Estate of Belcher v. CommissionerUnited States Tax Court · 1984
- Basdeo Balkissoon Gloria Balkissoon v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1993
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3Cited by3 opinions
- County of Westchester v. United States Department of Housing & Urban DevelopmentDistrict Court, S.D. New York · 2015
- Metzger v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1994
- Rosano v. United StatesDistrict Court, E.D. New York · 1999