Overview
Donee’s Liability for Unpaid Gift Tax and Interest Capped by Value of the Gift: The U.S. Court of Appeals for the Fifth Circuit held yesterday in United States v. Marshall that a donee’s liability for the donor’s unpaid gift tax and interest is capped by the amount of the gift. The case involved an indirect gift of stock that J. Howard Marshall II made to his heirs. Marshall did not pay gift taxes at the time he made the indirect gift and died shortly thereafter.