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Crummey v. C.I.R.

397 F.2d 82 (1968)

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Crummey v. C.I.R.

United States Court of Appeals for the Ninth Circuit

397 F.2d 82 (1968)

Facts

In 1962 the Crummeys created a trust for their four children. A demand provision allowed the children to demand distributions after funds were transferred into the trust each year until December 31. If a child was still a minor or otherwise lacked capacity, a guardian could make the demand on the child’s behalf. At the time, the federal gift-tax annual exclusion was $3,000. On December 15, 1962, the Crummeys deposited $49,550 into the trust. On December 19, 1963, the Crummeys deposited $12,797.81. Each year the Crummeys each claimed four $3,000 exemptions, totaling $24,000. The Commissioner of Internal Revenue (the Commissioner) (defendant) allowed only $3,000 for each parent in 1962 when only one child was over 21, and only $6,000 each in 1963 when two children were over 21. None of the children had made a demand against the trust funds. The Crummeys supported their children, and the minor children lived at home. No legal guardian had been appointed. The Crummeys petitioned to allow the remaining exemptions for the gifts to the children under 21. The United States Tax Court allowed an additional $3,000 each for 1962 because one child was 18 and had some limited rights under California law, but it denied exemptions for the gifts to children under 18. The Crummeys and the Commissioner cross-appealed.

Rule of Law

Issue

Holding and Reasoning (Byrne, J.)

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