United States v. Finley Hilliard

EDWARD C. PRADO, Circuit Judge:

In 1995, J. Howard Marshall, II (“J. Howard”) made what the IRS later determined was an indirect gift of Marshall Petroleum, Inc. (“MPI”) stock to MPI’s other shareholders: (1) Eleanor Pierce (Marshall) Stevens (“Stevens”), J. How'ard’s former wife, who was the beneficiary of a trust that was funded by MPI stock; (2) E. Pierce Marshall (“E. Pierce”), J. Howard’s son; (3) Elaine T. Marshall (“Elaine”), E. Pierce’s wife; (4) the Preston Marshall Trust (“Preston Trust”), which had been formed for the benefit of J. Howard’s grandson, Preston Marshall; and (5) the E.…