Legal Opinion
Autin v. Commissioner
Court of Appeals for the Fifth Circuit
Decided April 4, 1997No. 96-60265PublishedCited by 1 opinion
1Opinion of the Court
WISDOM, Circuit Judge:
Claude J. Autin appeals the tax court’s finding of a 1988 gift despite his asserted 1974 transfer of the subject property to his son by counterletter. For the reasons that follow, we REVERSE.
BACKGROUND
A. Proceedings and Disposition Below
On December 20, 1991, the Internal Revenue Service issued a notice of deficiency to the petitioner, Claude J. Autin, finding a deficiency in Mr. Autin’s 1988 gift tax and a delinquency addition to the tax under Internal Revenue Code § 6651(a)(1). 1
On March 4, 1992, the petitioner filed for redetermination in the United States Tax Court,…
2Cases cited28 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Burnet v. HarmelSupreme Court of the United States · 1932
- Morgan v. CommissionerSupreme Court of the United States · 1940
- United States v. BessSupreme Court of the United States · 1958
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
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3Cited by1 opinion
- Estate of Davenport v. CommissionerCourt of Appeals for the Tenth Circuit · 1999