Illinois Nat. Bank of Springfield v. United States

OPINION

RICHARD MILLS, District Judge:

Taxpayer suit for tax refund.

Civil action under 28 U.S.C. § 1346(a)(1) for recovery of a denied refund of estate taxes.

This cause is before the Court on competing motions for summary judgment.

Summary judgment for the government.

I. Issue

The basic issue before us is whether the trust funds that the decedent set up for her grand nieces and nephews are subject to a “substantial restriction,” as that term is used in treasury regulation 25.2503-4(b)(l), making them non-excludable taxable gifts?

II. Facts 1

Decedent set up trust accounts for twelve of her grand…