United States v. Hemme

Appellees, identified as the trustee of the “revocable living trust” of Charles W. Hirschi and transferees of Hirschi’s property, seek a refund of $6,000 in estate taxes, on the ground that the Government’s interpretation of a statutory transitional rule, enacted to bridge the old and new regimes for the federal taxation of gifts and estates, violates both the statute and the Constitution.

I

Prior to 1977, the gift tax and the estate tax were imposed, calculated, and collected separately. The gift tax, imposed on donors of certain gifts, permitted each taxpayer a lifetime exemption of $30,000…