Quimbee logo
DMCA.com Protection Status
From our private database of 18,800+ case briefs...

Diedrich v. Commissioner

United States Supreme Court
457 U.S. 191 (1982)


In 1972, Victor Diedrich and Frances Diedrich (plaintiffs) made gifts of stock to their children under the condition that their children pay the gift taxes associated with the transfer. The Diedrichs’ adjusted tax basis in the stock was $51,073. The gift tax paid by their children was $62,992. The commissioner for the Internal Revenue Service (defendant) issued a deficiency notice, holding that the children’s payment of the gift taxes, which were due to be paid by their parents, was a discharge of their parents’ indebtedness. The Diedrichs petitioned the United States Tax Court for a redetermination. The tax court held in favor of the Diedrichs, and the commissioner appealed. The United States Court of Appeals for the Eighth Circuit reversed in favor of the commissioner, resulting in a conflict among the federal circuit courts. The United States Supreme Court granted certiorari to resolve the conflict among the circuit courts.

Rule of Law


Holding and Reasoning (Burger, C.J.)

Dissent (Rehnquist, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 499,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 499,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial