DIEDRICH V. COMMISSIONER
457 U.S. 191 (1982)
NATURE OF THE CASE: This was a dispute over assignments of income on a gift property
transfer conditioned on payment of the gift tax by the donee.
FACTS: In 1972 Diedrich made gifts of 85,000 shares of stock to their three children by
direct transfers and trusts. The gifts were subject to the donees paying the federal and
state gift taxes. There is no dispute over the amount of the gift tax due. The gift tax paid
was $69,992. The basis in the transferred stock was $51,073. The court of Appeals Eighth
Circuit held that the donor realized income. Diedrich appealed.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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