Legal Opinion

Carpenter v. United States

United States Court of Claims

Decided April 15, 1985No. 691-81TPublishedCited by 11 opinions

1Opinion of the Court

OPINION

LYDON, Judge.

This tax case involves a suit for refund of certain gift taxes plus interest. The sole issue before the court is a determination of the value of the gift. In a previous opinion, Carpenter v. United States, 4 Cl.Ct. 705 (1984), the court concluded that the plaintiff, Ronald d’A. Carpenter,1 had made a gift of his one-third remainder interest in a 1927 trust, when he executed a trust agreement (1970 trust) on April 10, 1970, placing his remainder interest in an irrevocable trust for the benefit of himself, his then wife, Jeanne, and their two children. In rendering its…

2Cases cited24 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Dixon v. United StatesSupreme Court of the United States · 1965
  3. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
  4. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  5. Robinette v. HelveringSupreme Court of the United States · 1943

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3Cited by11 opinions

  1. Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
  2. Diebold, Inc. v. United StatesUnited States Court of Claims · 1989
  3. Easter House v. United StatesUnited States Court of Claims · 1987
  4. Hermes Consolidated, Inc. v. United StatesUnited States Court of Claims · 1988
  5. Lester H. Krabbenhoft Anna Krabbenhoft v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991

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