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ESTATE OF MUHAMMAD v. C.I.R.

Nos. 91-2560, 91-2561.

965 F.2d 520 (1992)

ESTATE OF Elijah MUHAMMAD, Deceased, Emanuel Muhammad, Administrator, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 19, 1992.

Attorney(s) appearing for the Case

Rufus Cook (argued), Chicago, Ill., for petitioner-appellant.

Abraham N.M. Shashy, Jr., I.R.S.; Gary R. Allen, Charles Bricken (argued), Steven W. Parks, and Gayle P. Miller, Department of Justice, Tax Div., Appellate Section, Washington, D.C., for respondent-appellee.

Before CUMMINGS and POSNER, Circuit Judges, and WILL, Senior District Judge.

WILL, Senior District Judge.

This is a consolidated appeal of two cases, one relating to gift taxes and the other to estate taxes. Elijah Muhammad was the leader of the Nation of Islam until his death in February 1975. Approximately six months before his death he conveyed title to four houses near his own to various relatives who also held positions within the Nation of Islam organization. The Internal Revenue Service contends that these were gifts, on which gift...

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