Ethel M. Warda v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
JOHN G. HEYBURN II, District Judge.
Petitioner Ethel Warda appeals the tax court’s determination that certain conveyances of land from Mrs. Warda to her son were taxable gifts. This Court is faced with two Michigan probate court decisions, one from 1953 and another from 1992, each of which, if followed here, would produce completely different results. The 1953 probate ruling declared that Mrs. Warda held title to the property the Commissioner now wishes to tax; the 1992 ruling declared that Mrs. War-da had not held title to the land in question but held the property in constructive trust for…
2Cases cited13 opinions
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