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ESTATE OF MONTGOMERY v. C. I. R.

No. 71-3259.

458 F.2d 616 (1972)

Estate of Lafayette MONTGOMERY, Deceased, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

April 18, 1972.

Attorney(s) appearing for the Case

M. E. Kilpatrick, Atlanta, Ga., for petitioners-appellants; Kilpatrick, Cody, Rogers, McClatchey & Regenstein, Atlanta, Ga., of counsel.

Scott P. Crampton, Asst. Atty. Gen., Tax Division, Dept. of Justice, Meyer Rothwacks, Loring W. Post, Attys., Tax Div., Dept. of Justice, Washington, D. C., K. Martin Worthy, Chief Counsel, Ray W. Sifly, Internal Revenue Service, Gary R. Allen, Dept. of Justice, Tax Div., Washington, D. C., for respondent-appellee.

Before JOHN R. BROWN, Chief Judge, and SIMPSON and MORGAN, Circuit Judges.

PER CURIAM:

Consideration of the issues raised on this appeal requires that we apply the "any form of contract or agreement" standard of Section 2039 of the Internal Revenue Code of 1954, Title 26, U.S.C., Section 2039, to an effort through use of a sophisticated device to utilize a claimed loophole in the federal estate tax statutes and thereby considerably reduce estate tax liability. We determine that the United States...

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