Legal Opinion
Rosen v. Commissioner
Court of Appeals for the Fourth Circuit
Decided June 14, 1968No. Nos. 12013-12016PublishedCited by 13 opinions
1Opinion of the Court
CRAVEN, Circuit Judge:
These consolidated appeals are taken from a decision of the Tax Court adverse to the taxpayers/appellants Leonard Rosen, Dorothy Rosen, Julius J. Rosen and Claire A. Rosen. The only issue presented for review is their entitlement to annual exclusions of up to $3,000 per donee in the computation of gift taxes. We hold that the taxpayers are entitled to the exclusions for the years in question, 1961, 1962 and 1963, in respect to the “income interests” of shares of Gulf American Land Corporation donated by the taxpayers to trusts created by them in 1961. We further hold…
2Cases cited11 opinions
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Weller v. CommissionerUnited States Tax Court · 1962
- McMurtry v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Rose Gelb, Victor Edwin Gelb, Manufacturers Trust Company, Executors, of the Estate of Harry Gelb v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
6 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of Daisy F. Christ, Deceased, Robert Johnson Christ v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
- Berzon v. CommissionerUnited States Tax Court · 1975
- Calder v. CommissionerUnited States Tax Court · 1985
- Alma M. O'Reilly v. Commissioner of Internal Revenue, Charles H. O'reilly, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
- Maryland National Bank and Ralph Norris, Personal Representatives of the Estate of Katherine L. N. Willis, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1980
8 more not listed; retrieve them via the Exa API.