Legal Opinion
Estate of Armstrong v. United States
Court of Appeals for the Fourth Circuit
Decided January 15, 2002No. 01-1305PublishedCited by 17 opinions
1Opinion of the Court
Affirmed by published opinion. Judge MOTZ wrote the opinion, in which Chief Judge WILKINSON and Judge HOWARD joined.
OPINION
DIANA GRIBBON MOTZ, Circuit Judge.
At the age of 91, Frank Armstrong, Jr. gave very substantial gifts of stock to his four children and, primarily through a trust he created, paid millions of dollars in gift taxes on those gifts. Armstrong died less than three years later, triggering estate taxes on those gift taxes. In addition, the IRS assessed additional gift taxes on the grounds that Armstrong undervalued the stock when the original gift taxes were paid. Armstrong’s…
2Cases cited8 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Robinette v. HelveringSupreme Court of the United States · 1943
- Diedrich v. CommissionerSupreme Court of the United States · 1982
- Harrison v. CommissionerUnited States Tax Court · 1952
3 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Scott v. United StatesCourt of Appeals for the Fourth Circuit · 2003
- Scott v. United StatesCourt of Appeals for the Fourth Circuit · 2003
- McCord v. Comm'rUnited States Tax Court · 2003
- Estate of Morgens v. Comm'rUnited States Tax Court · 2009
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
12 more not listed; retrieve them via the Exa API.