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ESTATE OF CEPPI

No. 82-1453.

698 F.2d 17 (1983)

ESTATE OF Jane B. CEPPI, Deceased. Peter B. CEPPI, Executor, Plaintiff, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided January 11, 1983.

Attorney(s) appearing for the Case

G. Quentin Anthony, Jr., with whom Sheffield & Harvey, Newport, R.I., was on brief, for plaintiff, appellant.

Nathanael R. Brayton, with whom John H. Clymer, and Hutchins & Wheeler, Boston, Mass., were on brief for plaintiff, appellant, amicus curiae.

Elaine F. Ferris, Albany, Cal., with whom Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, and Robert T. Duffy, Washington, D.C., were on brief, for defendant, appellee.

Before BOWNES, BROWN and BREYER, Circuit Judges.

BAILEY BROWN, Senior Circuit Judge.

In this estate tax case, the decedent, shortly before death, made gifts each in excess of $3000 to eight individuals. It is without dispute that the gifts are generally includable in the decedent's gross estate. The issue is whether $3000 of each gift is to be excluded from the gross estate. The estate tax statute contains an exclusion provision applicable to gifts that are to be included in the gross estate, and this exclusion...

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