United States Third Circuit

In a suit for tax deficiency, plaintiff's inter vivos transfers do not qualify for the 26 U.S.C. section 2036(a) exception where neither of its partnerships conducted any legitimate business operations, nor provided plaintiff with any potential non-tax benefit from the transfers.

Appellate Information

• Argued 04/21/2004
• Decided 09/01/2004
• Published 09/01/2004

Judges

• SCIRICA, Chief Judge., Before SCIRICA, Chief Judge, ROSENN and GREENBERG, Circuit Judges.

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• Victor F. Keen, (Argued), Thomas W. Ostrander, Duane Morris LLP, Philadelphia, PA, for Appellant.


• For Appellees:
  
• Michael J. Haungs, (Argued), Jonathan S. Cohen, United States Department of Justice, Tax Division, Washington, DC, for Appellee.