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EVANSON v. U.S.

No. 93-2689.

30 F.3d 960 (1994)

Carroll EVANSON, as Co-Personal Representative of the Estate of Alfred Eide, Deceased, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eighth Circuit.

Decided July 21, 1994.

Attorney(s) appearing for the Case

Kenneth Rosenberg, Washington, DC, argued, for appellant.

Michael Wagner, Bismarck, ND, argued, for appellee.

Before MAGILL, Circuit Judge, and FLOYD R. GIBSON and JOHN R. GIBSON, Senior Circuit Judges.

FLOYD R. GIBSON, Senior Circuit Judge.

The government appeals the district court's summary judgment in favor of the personal representative of Alfred Eide's Estate (the "estate"). This dispute involves the interplay between the federal gift tax and estate tax statutes. We reverse and remand.

I. BACKGROUND

In January 1981, Alfred Eide made two gifts of mineral rights and filed a federal gift tax return that listed their total taxable value as $14...

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