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MAY v. C. I. R.

No. 82-7658.

723 F.2d 1434 (1984)

Lewis H.V. MAY and Nancy C. May, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Ninth Circuit.

Decided January 20, 1984.

Attorney(s) appearing for the Case

Henry P. Pramov, Jr., Los Angeles, Cal., for appellees.

Jonathan Cohen, Washington, D.C., for appellant.

Before KENNEDY, SKOPIL, and PREGERSON, Circuit Judges.

PREGERSON, Circuit Judge:

I. FACTS

This case presents a typical "gift-leaseback" situation. In 1971, the taxpayers, Dr. Lewis H.V. and Nancy C. May, deeded their entire title and interest in improved real property, located in Temple City, California, to an irrevocable trust for the benefit of their four children. The trust instrument appointed Dr. May and a friend, Harlos Gross, as co-trustees. Although executed and delivered in 1971, the deed was not recorded...

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