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KRABBENHOFT v. C.I.R.

No. 90-2876.

939 F.2d 529 (1991)

Lester H. KRABBENHOFT; Anna Krabbenhoft, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 27, 1991.

Rehearing and Rehearing Denied August 9, 1991.

Attorney(s) appearing for the Case

Bruce Carlson, argued (Bruce H. Carlson and David J. Hauff, on the brief), Fargo, N.D., for appellants.

Richard Farber, argued (Gary R. Allen, Richard Farber and Teresa T. Milton, on the brief), Washington, D.C., for appellee.

Before FAGG, and MAGILL, Circuit Judges, and HENLEY, Senior Circuit Judge.

Rehearing and Rehearing En Banc Denied August 9, 1991.

MAGILL, Circuit Judge.

Lester and Anna Krabbenhoft appeal the Tax Court's1 decision affirming the Commissioner's assessment of gift tax liability against each of them. The Krabbenhofts challenge on appeal the Tax Court's determination that 26 U.S.C. § 483's "safe harbor" interest rate does not apply to the valuation of a contract...

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