JEWETT v. C. I. R.

No. 78-3621.

638 F.2d 93 (1980)

George F. JEWETT, Jr., and Lucille M. Jewett, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided December 9, 1980.

Rehearing Denied February 18, 1981.


Attorney(s) appearing for the Case

Robert J. Richards, Jr., Boston, Mass., for petitioners-appellants.

Jonathan S. Cohen, Tax Div. Dept. of Justice, Washington, D. C., argued for respondent-appellee; Suzanne G. Duvall, Washington, D. C., on brief.

Before BROWNING and MERRILL, Circuit Judges, and HARRIS, District Judge.


MERRILL, Circuit Judge:

This is an appeal from a decision of the Tax Court holding that appellant George F. Jewett, Jr., made taxable gifts when he executed disclaimers of his remainder interest in a testamentary trust.1 We affirm.

The facts are not in dispute. Appellant's grandmother, Margaret Jewett, a resident of Massachusetts, died in 1939, and by her will created a trust with income to go to her husband, James, during his...

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