Mary Ann Heyen, of the Estate of Jennie Owen, Deceased v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• indicating that gift of stock is complete when stock is transferred into donee’s name on corporation’s books
• disregarding as shams 27 transfers of stock to intermediate beneficiaries who then transferred the stock to the original transferor's family
• applying only substance over form analysis to a gift of stock to disregard intermediate transferees
• treating the decedent’s inter vivos transfers of stock shares to multiple nonfamily members, who -20- [ ] immediately reconveyed the shares to members of the decedent’s family, as indirect transfers from the decedent to the ultimate donees
• decedent's transfers of blocks of stock each worth less than $ 10,000 were subject to gift tax where purported donees retransferred the stock to decedent's family members
• donor transferred stock to 29 straws who either did not know they were receiving stock or believed that they were participating in stock transfers or had agreed before receiving the stock to its retransfer, 27 of whom then retransferred the stock to the donor's intended donees

Source: CourtListener parenthetical corpus (CC0).