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WALLACE v. UNITED STATES

Civ. A. No. 76-4088-K.

566 F.Supp. 904 (1981)

Monte J. WALLACE, Anne H. Wallace, Neil W. Wallace, and Elise R. Wallace, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Massachusetts.

December 18, 1981.

Attorney(s) appearing for the Case

M. Gordon Ehrlich, John S. Brown, Bingham, Dana & Gould, Paul Lambert, Boston, Mass., for plaintiffs.

Ralph A. Child, Asst. U.S. Atty., Boston, Mass., Steven Z. Kaplan, Michael E. Weitzner, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant.

Opinion

KEETON, District Judge:

This is an action brought pursuant to 26 U.S.C. § 7402 for the recovery of gift taxes paid by plaintiffs on gifts made in October and November 1972. The court has jurisdiction under 28 U.S.C. § 1346(a)(1). At issue is the value of gifts of stock made by plaintiffs to two trusts established for their respective children.

Findings of fact (based on evidence presented...

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