Metzger v. Commissioner
United States Court of Appeals for the Fourth Circuit
38 F.3d 118 (1994)
- Written by Daniel Clark, JD
Facts
On December 14, 1985, Albert Metzger’s agent, acting on Albert’s behalf, wrote and delivered several checks. The checks were each for $10,000 and were given as gifts. Two of the recipients were Albert’s son, John, and John’s wife. John and his wife deposited their checks on December 31, 1985. However, the checks did not clear until January 2, 1986. Albert treated the checks as having been gifted in 1985 for the purpose of claiming the $10,000 gift-tax exclusion. Later in 1986, Albert gave John and his wife each another $10,000 check as a gift, which they deposited during the year. Albert treated these checks as having been gifted in 1986 for the purpose of claiming the $10,000 gift-tax exclusion. After Albert died, the Internal Revenue Service (IRS) (defendant) audited his estate tax return. The IRS determined that all four checks were gifted in 1986. Accordingly, with respect to both John and his wife, the IRS determined that Albert had exceeded the gift-tax exclusion for 1986 by $10,000 and issued a deficiency against Albert’s estate (plaintiff). The estate challenged the IRS in tax court, which found in favor of the estate. The IRS appealed.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
What to do next…
Here's why 832,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 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.
