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METZGER v. COMMISSIONER OF I.R.S.

No. 93-2112.

38 F.3d 118 (1994)

John A. METZGER; Z. Townsend Parks, Jr., Personal Representatives for the Estate of Albert F. Metzger, Deceased, Petitioners-Appellees, v. COMMISSIONER OF the INTERNAL REVENUE SERVICE, Respondent-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided September 1, 1994.

Corrected Opinion Filed October 18, 1994.

Attorney(s) appearing for the Case

ARGUED: Thomas J. Clark, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellant. Luther Benjamin Ditch, Parks, Hansen, Ditch & Zaharris, Towson, MD, for appellees. ON BRIEF: Michael L. Paup, Acting Asst. Atty. Gen., Gary R. Allen, Richard Farber, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellant.

Before LUTTIG and WILLIAMS, Circuit Judges, and PAYNE, United States District Judge for the Eastern District of Virginia, sitting by designation.

Affirmed by published opinion. Judge WILLIAMS wrote the majority opinion, in which Judge PAYNE joined. Judge LUTTIG wrote a separate dissenting opinion.

OPINION

WILLIAMS, Circuit Judge:

This is an appeal by the Commissioner of Internal Revenue from a decision of the United States Tax Court in favor of the taxpayer, the estate of Albert F. Metzger. The issue presented is whether noncharitable gifts in the form of checks are complete for federal gift...

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