Legal Opinion
Estate of Cyril I. Magnin, Deceased Donald Isaac Magnin v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided July 13, 1999No. 96-70578PublishedCited by 33 opinions
1Opinion of the Court
SCHROEDER, Circuit Judge:
This tax appeal concerns the interpretation of Section 2036 of the Internal Revenue Code, which imposes an estate tax on the full value of property that a decedent transferred during his life while retaining a life interest. The section contains an exception for transfers for which the decedent had received full and adequate consideration. See 26 U.S.C. § 2036(a).
The major issue we must decide is how to measure whether the decedent, Cyril Magnin, received full and adequate consideration under an agreement entered into between Cyril and his father, Joseph Mag-nin. In…
2Cases cited24 opinions
- United States v. JanisSupreme Court of the United States · 1976
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Merrill v. FahsSupreme Court of the United States · 1945
- Longview Fibre Co. v. RasmussenCourt of Appeals for the Ninth Circuit · 1992
19 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Sorenson v. MinkCourt of Appeals for the Ninth Circuit · 2001
- Sorenson v. MinkCourt of Appeals for the Ninth Circuit · 2001
- Cook v. United StatesUnited States Court of Federal Claims · 2000
- Estate of Abraham v. CommissionerCourt of Appeals for the First Circuit · 2005
- United States v. Antonio Andrew SmithCourt of Appeals for the Ninth Circuit · 2003
28 more not listed; retrieve them via the Exa API.