Legal Opinion

Ross v. Commissioner

United States Tax Court

Decided February 21, 1979No. Docket Nos. 1153-76, 1200-76Published

Petitioners made gifts in trust for the benefit of their minor grandchildren. Held, the term "heirs at law" is not equivalent to the term "estate" for purposes of sec. 2503(c)(2)(B), I.R.C. 1954, and, therefore, gifts in issue not eligible for annual exclusion.

1Opinion of the Court

Cornelius A. Ross, Petitioner v. Commissioner of Internal Revenue, Respondent; Effie H. Ross, Petitioner v. Commissioner of Internal Revenue, Respondent

Ross v. Commissioner

Docket Nos. 1153-76, 1200-76

United States Tax Court

71 T.C. 897; 1979 U.S. Tax Ct. LEXIS 168;

February 21, 1979, Filed

Decisions will be entered under Rule 155.

Petitioners made gifts in trust for the benefit of their minor grandchildren. Held, the term "heirs at law" is not equivalent to the term "estate" for purposes of sec. 2503(c)(2)(B), I.R.C. 1954, and, therefore, gifts in issue not eligible for annual exclusion.

Joseph H.…

2Cases cited3 opinions

  1. Clinard v. CommissionerUnited States Tax Court · 1963
  2. Heath v. CommissionerUnited States Tax Court · 1960
  3. Ross v. CommissionerUnited States Tax Court · 1979

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