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ESTATE OF MORGENS v. C.I.R.

No. 10-73698.

678 F.3d 769 (2012)

ESTATE OF Anne W. MORGENS, Deceased, James H. Morgens, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 3, 2012.

Attorney(s) appearing for the Case

John W. Porter , Keri D. Brown , and Jeffrey D. Watters, Jr. , Baker Botts L.L.P., Houston, TX, for the petitioner-appellant.

Gilbert S. Rothenberg , Acting Deputy Assistant Attorney General, Jonathan S. Cohen , and Bethany B. Hauser , Washington, D.C., for the respondent-appellee.

Before: MARSHA S. BERZON and CARLOS T. BEA, Circuit Judges, and LLOYD D. GEORGE, Senior District Judge.

OPINION

BEA, Circuit Judge.

The Estate of Anne W. Morgens ("the Estate") appeals the United States Tax Court's decision that it owed additional estate taxes. This case presents the question whether gift taxes paid by the donee trustees of a Qualifying Terminable Interest in Property (QTIP) trust, based on a 26 U.S.C. § 25191 deemed inter vivos transfer of the QTIP property within three years of the donor's death,...

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