Net Gift Doctrine Not Applicable If Obligation Too Speculative

Business Valuation UpdateVol. 8 No. 5
Legal and Court Case Update
May 2002
5148 Fresh Fruits and Vegetables
424480 Fresh Fruit and Vegetable Merchant Wholesalers
estate and gift taxation
gift tax

Estate of Armstrong v. United States
277 F.3d 490, 2002 U.S. App. LEXIS 636
January 15, 2002
Federal Court
4th Circuit
United States Court of Appeals


Decedent held a controlling interest in National Fruit Products Inc., a privately held corporation.

See Also

Estate of Armstrong v. United States

The estate argued the "net gift doctrine," contending that the children's obligation to pay additional gift taxes as a condition of the gifts had substantially reduced the value of ...