Legal Opinion
Wallace v. United States
District Court, D. Massachusetts
Decided December 18, 1981No. Civ. A. 76-4088-KPublishedCited by 8 opinions
1Opinion of the Court
Opinion
KEETON, District Judge:
This is an action brought pursuant to 26 U.S.C. § 7402 for the recovery of gift taxes paid by plaintiffs on gifts made in October and November 1972. The court has jurisdiction under 28 U.S.C. § 1346(a)(1). At issue is the value of gifts of stock made by plaintiffs to two trusts established for their respective children.
Findings of fact (based on evidence presented during a five-day bench trial) and conclusions of law are set forth in narrative form in this opinion.
I. Background Facts
Plaintiffs are two brothers, Monte J. and Neil W. Wallace, and their respective…
2Cases cited11 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- United States v. Gordon Simmons and I. v. Simmons, Executors of the Estate of B. Hill SimmonsCourt of Appeals for the Fifth Circuit · 1965
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Estate of Simplot v. Comm'rUnited States Tax Court · 1999
- Okerlund v. United StatesUnited States Court of Federal Claims · 2002
- National Rural Utilities Cooperative Finance Corp. v. Wabash Valley Power Ass'n (In Re Wabash Valley Power Ass'n)District Court, S.D. Indiana · 1990
- Becker v. United StatesDistrict Court, D. Nebraska · 1990
- Estate of Richard R. Simplot v. CommissionerUnited States Tax Court · 1999
3 more not listed; retrieve them via the Exa API.