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ROST v. UNITED STATES

No. 21-51064.

44 F.4th 294 (2022)

Daphne Jeanette ROST, Executor of the Estate of John H. Rebold, Plaintiff-Appellant, v. UNITED STATES of America, the Internal Revenue Service, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

FILED August 11, 2022.

Attorney(s) appearing for the Case

Joseph M. Erwin , Erwin Law Firm, Dallas, TX, for Plaintiff-Appellant.

Lauren E. Hume , Jennifer Marie Rubin, Esq. , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Herbert W. Linder , U.S. Department of Justice Tax Division, Dallas, TX, for Defendant-Appellee.

Before Smith, Duncan, and Oldham, Circuit Judges.

In 2005, John Rebold formed the Enelre Foundation as a Stiftung under the laws of Liechtenstein. Stiftung is a German word meaning, roughly, "foundation" or "endowment." Enelre's purpose is to provide education and general support for Rebold and his children. Rebold transferred $3 million to Enelre...

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