Estate of Gawne v. Commissioner
United States Tax Court
Decedent's wife made a gift between Sept. 8, 1976, and Jan. 1, 1977, which was considered as made one-half by the decedent pursuant to an election under sec. 2513, I.R.C. 1954. Decedent used $ 18,389.38 of his specific exemption for gift taxes in connection with this gift.
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Decedent's wife made a gift between Sept. 8, 1976, and Jan. 1, 1977, which was considered as made one-half by the decedent pursuant to an election under sec. 2513, I.R.C. 1954. Decedent used $ 18,389.38 of his specific exemption for gift taxes in connection with this gift. Held, for purposes of estate taxes, the amount allowed as a specific exemption for a gift "considered as made" by the donor's spouse causes a reduction in the amount of the unified credit for the nondonor under sec. 2010(c), I.R.C. 1954; therefore, the amount of specific exemption used by decedent should be considered in…
1Opinion of the Court
Estate of James O. Gawne, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Gawne v. Commissioner
Docket No. 13172-81
United States Tax Court
80 T.C. 478; 1983 U.S. Tax Ct. LEXIS 111; 80 T.C. No. 19;
March 3, 1983, Filed
Decision will be entered for the respondent.
Decedent's wife made a gift between Sept. 8, 1976, and Jan. 1, 1977, which was considered as made one-half by the decedent pursuant to an election under sec. 2513, I.R.C. 1954. Decedent used $ 18,389.38 of his specific exemption for gift taxes in connection with this gift. Held, for purposes of estate taxes, the amount…
2Cases cited5 opinions
- Renick v. United StatesUnited States Court of Claims · 1982
- Rachel H. Ingalls v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1964
- Ingalls v. CommissionerUnited States Tax Court · 1963
- Norair v. CommissionerUnited States Tax Court · 1976
- Estate of Gawne v. CommissionerUnited States Tax Court · 1983