United States Ninth Circuit
SCHOTT v. COMM'R OF INTERNAL REVENUE, 02-70007
A two-life annuity retained by taxpayers in grantor-retained annuity trusts was an interest qualified under Treasury Regulations section 25.2702, and so can be subtracted from the value of the gift.
Appellate Information
- Argued 01/15/2003
- Decided 02/18/2003
- Published 02/18/2003
Judges
- NOONAN, Circuit Judge., Before SCHROEDER, Chief Judge, NOONAN and CLIFTON, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- George N. Harris, Jr., Kozusko Lahey Harris LLP, Washington, D.C., for the petitioners-appellants., Ellen K. Harrison, Amicus Curiae The American College of Trust and Estate Counsel.
- For Appellees:
- Rachel Wollitzer, Attorney, Tax Division, Department of Justice, Washington, D.C., for the respondent-appellee.