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Maryland National Bank v. United States
United States Court of Appeals for the Fourth Circuit
609 F.2d 1078 (1979)
Facts
Katherine Willis transferred her half of a partnership interest into an inter vivos trust and named 17 relatives as the trust’s beneficiaries. The partnership’s assets included farmland and a large recreational complex. These assets generated income. However, during a recent eight-year span, the partnership had made a profit from its income in only one of the eight years. The one year that the partnership made a profit, it reinvested the profit instead of distributing it. When Willis calculated her gift-tax liability on her transfer of the partnership interest to the trust, she deducted $3,000—the maximum annual exclusion for gifts to a single recipient—for each of the 17 recipients and paid gift tax on the remainder of the transferred value. The federal government (defendant) determined that Willis’s gift did not qualify for any gift-tax exclusions because Willis had not gifted any present property interests. Therefore, Willis owed gift taxes on the gift’s full value. Willis’s estate (plaintiff) filed a lawsuit in federal district court asserting Willis’s right to the gift-tax exclusions. The district court ruled that Willis had not gifted any present interests and, therefore, that the entire gift was taxable. Willis’s estate appealed.
Rule of Law
Issue
Holding and Reasoning (Butzner, J.)
Dissent (Hall, J.)
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