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ESTATE OF BOWGREN v. C.I.R.

No. 96-1366.

105 F.3d 1156 (1997)

ESTATE OF Helen E. BOWGREN, Deceased, Warren D. Bowgren, Executor, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided January 24, 1997.

Attorney(s) appearing for the Case

Thomas F. Joyce, Robert L. Wiesenthal (argued), Bell, Boyd & Lloyd, Chicago, IL, for Petitioner-Appellee.

Stuart L. Brown, Curtis G. Wilson, Internal Revenue Service, Gary R. Allen, Jonathan S. Cohen, Curtis C. Pett (argued), Department of Justice, Tax Division, Appellate Section, Loretta C. Argrett, Department of Justice, Tax Division, Washington, DC, for Respondent-Appellant.

Before EASTERBROOK, RIPPLE and ROVNER, Circuit Judges.

RIPPLE, Circuit Judge.

Helen E. Bowgren, deceased, created an Illinois land trust in 1975 and divided the trust's beneficial interest into ninety-eight units. Between 1975 and 1979, she transferred some of those units to her three children. She died testate on April 8, 1990. Mrs. Bowgren's estate disclosed the transfer of those units but excluded their value from the gross estate. The Commissioner of Internal Revenue ("CIR...

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