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Juanelle TUBBS, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee

United States Court of Appeals for the Fifth Circuit1973-01-15No. No. 72-3232
472 F.2d 166

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Opinion

majority opinion

PER CURIAM:

The facts in this estate tax refund suit are well summarized in the district court’s opinion, 348 F.Supp. 1404. Those facts establish conclusively the existence of an implied agreement that the transferor was to have lifetime enjoyment of the property. Guynn v. United States, 4th Cir. 1971, 437 F.2d 1148. Thus, the value of the property was properly includible in the transferor’s estate, and the district court properly directed a verdict in appellee’s favor. Affirmed.