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Walton v. Commissioner, 115 T.C. 589 (2000), a decision of the United States Tax Court in favor of taxpayer Audrey J. Walton, "ruled that a grantor's right to receive a fixed amount for a term of years, if that right is a qualified interest within the meaning of Section 2702(b), is valued for gift tax purposes under Section 7520, without regard to the life expectancy of the transferor." More simply, a grantor's estate's contingent interest in a grantor-created annuity upon the grantor's death does not constitute a gift to anyone; but rather, is a retained interest of the grantor.

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  • Walton v. Commissioner
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  • Walton v. Commissioner, 115 T.C. 589 (2000), a decision of the United States Tax Court in favor of taxpayer Audrey J. Walton, "ruled that a grantor's right to receive a fixed amount for a term of years, if that right is a qualified interest within the meaning of Section 2702(b), is valued for gift tax purposes under Section 7520, without regard to the life expectancy of the transferor." More simply, a grantor's estate's contingent interest in a grantor-created annuity upon the grantor's death does not constitute a gift to anyone; but rather, is a retained interest of the grantor.
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  • Walton v. Commissioner
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  • Walton v. Commissioner, 115 T.C. 589
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  • United States Tax Court
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  • Walton v. Commissioner, 115 T.C. 589 (2000), a decision of the United States Tax Court in favor of taxpayer Audrey J. Walton, "ruled that a grantor's right to receive a fixed amount for a term of years, if that right is a qualified interest within the meaning of Section 2702(b), is valued for gift tax purposes under Section 7520, without regard to the life expectancy of the transferor." More simply, a grantor's estate's contingent interest in a grantor-created annuity upon the grantor's death does not constitute a gift to anyone; but rather, is a retained interest of the grantor.
full name
  • Audrey J. Walton v. Commissioner of Internal Revenue
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  • a unanimous court
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