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SCHOTT v. C.I.R.

No. 02-70007.

319 F.3d 1203 (2003)

Patricia A. SCHOTT, Stephen C. Schott, Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed February 18, 2003.

Attorney(s) appearing for the Case

George N. Harris, Jr., Kozusko Lahey Harris LLP, Washington, D.C., for the petitioners-appellants.

Rachel Wollitzer, Attorney, Tax Division, Department of Justice, Washington, D.C., for the respondent-appellee.

Ellen K. Harrison, Amicus Curiae The American College of Trust and Estate Counsel.

Before SCHROEDER, Chief Judge, NOONAN and CLIFTON, Circuit Judges.

NOONAN, Circuit Judge.

Stephen C. Schott and Patricia A. Schott petition for review of a judgment of the Tax Court sustaining a deficiency in gift tax assessed by the Commissioner of Internal Revenue (the Commissioner). The question presented is whether the two-life annuity retained by the Schotts in their grantor-retained annuity trusts (GRATs) is an interest qualified under 26 U.S.C. § 2702 and so to be subtracted from the value of the gift. We hold that the...

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