United States Fourth Circuit
ESTATE OF FRANK ARMSTRONG, JR. v. US, 01-1305
Gift transfer conditioned on donees paying any additional gift tax that the IRS determined the estate did not pay, is too speculative to be subject to the "net gift" doctrine.
Appellate Information
- Argued 10/30/2001
- Decided 01/15/2002
- Published 01/15/2002
Judges
- Before WILKINSON, Chief Judge, MOTZ, Circuit Judge, and MALCOM J. HOWARD, United States District Judge for the Eastern District of North Carolina, sitting by designation.
Court
- United States Fourth Circuit
Counsel
- For Appellees:
- ARGUED: Stephen L. Pettler, Jr., Harrison & Johnston, Winchester, Virginia, for Appellants. Joan Iris Oppenheimer, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Aubrey J. Owen, Owen & Truban, P.L.C., Winchester, Virginia, for Appellants. Claire Fallon, Acting Assistant Attorney General, Richard Farber, Ruth E. Plagenhoef, United States Attorney, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.