COOK v. COOM'R OF THE INTERNAL REVENUE SERV., 01-1471
The terms of spousal interests must be fixed and ascertainable at the time of creations of Grantor Retained Annuity Trusts, or they are not "qualified interests" within the meaning of 26 USC 2702, and are not entitled to exemption from gift tax liability.
- Decided 10/22/2001
- Published 10/22/2001
- FLAUM, Chief Judge., Before FLAUM, Chief Judge, and MANION, and WILLIAMS, Circuit Judges.
- United States Seventh Circuit
- For Appellant:
- George N. Harris, Jr. (argued), Kozusko Lahey Harris, Washington, DC, for Petitioners-Appellants.
- For Appellees:
- Jonathan S. Cohen (argued), Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.