United States Eighth Circuit

Where similar stock transfers by two brothers to each other's children left deceased brother's children in approximately the same economic position as if the transfers had made directly to them, transfers were reciprocal cross-gifts taxable to decedent's estate.

Appellate Information

• Decided 03/07/2002
• Published 03/07/2002

Judges

• RILEY, Circuit Judge., Before LOKEN, HEANEY, and RILEY, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Garry A. Pearson, argued, Grand Forks, ND (Alexander F. Reichert, Grand Forks, ND, on the brief), for appellants.


• For Appellees:
  
• Karen D. Utiger, USDOJ, Tax Div., argued, Washington, DC (Thomas J. Clark, USDOJ, on the brief), for appellee.