Legal Opinion
Mercantile-Safe Deposit and Trust Co. v. United States
District Court, D. Maryland
Decided April 13, 1970No. Civ. 19789PublishedCited by 5 opinions
1Opinion of the Court
THOMSEN, Chief Judge.
This is a refund suit brought by the executors of the estate of Ellen A. Schoeneman, the executors of the estate of Ansel Schoeneman, and Jay Jefferson Miller and Josepha S. Miller individually, against the United States for the recovery of gift taxes and assessed interest for the years 1963 and 1964.
The question presented is whether in computing their gift tax liabilities, the annual exclusion of $3,000 per donee was available to the taxpayers with respect to their transfers in trust in 1963 and 1964. The answer turns on whether the donees’ interests in the trusts were…
2Cases cited11 opinions
- Commissioner v. DisstonSupreme Court of the United States · 1945
- 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
- Jones v. NorrisCourt of Appeals for the Tenth Circuit · 1941
- Gilmore v Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- George Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
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3Cited by5 opinions
- Lera H. Stark v. United States of America, William P. Stark v. United StatesCourt of Appeals for the Eighth Circuit · 1973
- Martinez v. CommissionerUnited States Tax Court · 1976
- Swetland v. CommissionerUnited States Tax Court · 1978
- Willis v. United StatesDistrict Court, D. Maryland · 1978
- Martinez v. CommissionerUnited States Tax Court · 1976