Legal Opinion
Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided December 30, 1963No. 17121, 17122PublishedCited by 195 opinions
1Opinion of the Court
BLACKMUN, Circuit Judge.
The Tax Court has upheld asserted deficiencies in the 1953 federal gift taxes of Marie H. Hamm and William Hamm, Jr., in the respective amounts of $317,-281.96 and $456,138.53. Judge Pierce’s opinion, 79 pages in length and not reviewed by the full court, is T. C. Memo 1961-347. Each taxpayer has petitioned for review.
The Hamms are husband and wife and residents of Minnesota. Each filed a timely gift tax return for 1953. By these returns they consented, as § 1000(f) of the Internal Revenue Code of 1939 permitted, that gifts made by either of them to third persons…
2Cases cited31 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. TaylorSupreme Court of the United States · 1935
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Wickwire v. ReineckeSupreme Court of the United States · 1927
26 more not listed; retrieve them via the Exa API.
3Cited by195 opinions
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Chester D. Tripp, Chester D. Tripp, Surviving Spouse Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
190 more not listed; retrieve them via the Exa API.