United States First Circuit

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Cavallaro v. Commissioner of Internal Revenue, 15-1368

In a married couple's appeal from a Tax Court decision affirming a determination by the Internal Revenue Service (IRS) Commissioner that plaintiffs owed gift taxes on a $29,670,000 gift to their sons, the Tax Court decision is: 1) affirmed as to the court's determination that the burden of proof was on the taxpayers and its finding that plaintiffs' company owned certain technology at the time of the merger with the sons' company; and 2) reversed insofar as the court misstated the nature of the plaintiffs' burden of proof, and remand the case for further proceedings.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2016/11/18




  • United States First Circuit


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