Imposition of Gift Tax (Imposed v. Not Imposed)

ID:
Office:
UILC:
CCA_2014011513380665
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2501.00-00
Number: 201412015
Release Date: 3/21/2014
From: ---
Sent: Wednesday, January 15, 2014 1:38:09 PM
To: ---
Cc: ---
Subject: K Case
As I related in a phone conversation with ---, we believe that there are grounds for allowing the taxpayer to refund the gift taxes. We believe that the local court has properly applied state law in rescinding the gift.
However, no refund should actually be granted to the taxpayer until such time as the taxpayer recoups the funds from the original gift. The statute of limitations should be extended so that taxpayer can apply for refund when the gift is returned to the taxpayer.
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