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Estate of Sachs v. Commissioner

88 T.C. 769 (1987)

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Estate of Sachs v. Commissioner

United States Tax Court

88 T.C. 769 (1987)

Facts

Samuel Sachs gifted property totaling more than $2 million to three trusts for the benefit of his grandchildren. The transfers were structured as net gifts. This meant that the gift’s recipients, the trusts, used approximately $600,000 of the transferred property to pay the gift taxes that Sachs owed on the gift transfer. Less than three years later, Sachs died. The commissioner of Internal Revenue (commissioner) (defendant) determined that, under 26 U.S.C. § 2035(b), the $600,000 gift-tax payment was a tax payment on a deathbed gift and should be included in Sachs’s gross estate. Sachs’s estate (plaintiff) petitioned the United States Tax Court for a determination that the gift-tax payment was not part of the gross estate. The estate argued that the clear, unambiguous language of § 2035(b) included gift-tax payments on deathbed gifts only if a payment was made by the decedent or his estate. Because the trusts, not Sachs or his estate, had made the $600,000 payment, the statute did not apply to the payment.

Rule of Law

Issue

Holding and Reasoning (Cohen, J.)

Concurrence (Hamblen, J.)

Dissent (Chabot, J.)

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