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SATHER v. COMMISSIONER OF INTERNAL REVENUE

No. 00-2171.

251 F.3d 1168 (2001)

Larry L. SATHER, Donor, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Sandra Sather, Donor, Appellant, v. Commissioner of Internal Revenue, Appellee. John Sather, Donor, Appellant, v. Commissioner of Internal Revenue, Appellee. Kathy Sather, Donor, Appellant, v. Commissioner of Internal Revenue, Appellee. Duane K. Sather, Donor, Appellant, v. Commissioner of Internal Revenue, Appellee. Diane R. Sather, Donor, Appellant, v. Commissioner of Internal Revenue, Appellee. Duane K. Sather Irrevocable Trust, U/A 12/27/91, Transferee, John R. Sather, Trustee, Appellant, v. Commissioner of Internal Revenue, Appellee. Larry L. Sather Irrevocable Trust, U/A 12/27/91, Transferee, Rodney J. Sather, Trustee, Appellant, v. Commissioner of Internal Revenue, Appellee. John R. Sather Irrevocable Trust, U/A 12/27/91, Transferee, Rodney J. Sather, Trustee, Appellant, v. Commissioner of Internal Revenue, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: June 7, 2001.

Attorney(s) appearing for the Case

Thomas F. Arends, Schaumburg, Illinois, argued, for appellant.

Karen D. Utiger, Washington, D.C., argued (Paula M. Junghans and Thomas J. Clark, on the brief), for appellee.

Before WOLLMAN, Chief Judge, HANSEN and MURPHY, Circuit Judges.

HANSEN, Circuit Judge.

The Internal Revenue Service (IRS) imposed gift tax deficiencies and accuracy-related penalties on Larry Sather, Kathy Sather, John Sather, Sandra Sather, Duane Sather, and Diane Sather related to gifts made by each of them in 1993, and assessed transferee liability for gift tax deficiencies and penalties against the Duane K. Sather Irrevocable Trust (the Duane Trust), the Larry L. Sather Irrevocable Trust (the Larry Trust), and the John R....

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