Legal Opinion
Fatter v. Usry
District Court, E.D. Louisiana
Decided June 14, 1967No. Civ. A. 14188, 14189PublishedCited by 4 opinions
1Opinion of the Court
RUBIN, District Judge:
The sons of Anthony A. Fatter and his wife, Pauline J. Marchand Fatter, contend that gifts to them by their parents were not made in contemplation of death and therefore that estate taxes paid with reference to these gifts should be refunded.
The defendant, sued in his capacity as District Director of Internal Revenue, assessed the tax under the provisions of Section 2035 of the Internal Revenue Code which provides, in relevant part, that: “The value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent has…
2Cases cited19 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Heiner v. DonnanSupreme Court of the United States · 1932
- Milliken v. United StatesSupreme Court of the United States · 1931
- Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
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3Cited by4 opinions
- Bel v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Bel v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Brewer v. PetersonCourt of Appeals of Arizona · 1969
- First National Bank at Lubbock, Trustee v. United StatesCourt of Appeals for the First Circuit · 1972