Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United States

397 F.2d 443
CourtCourt of Appeals for the Seventh Circuit
DecidedNovember 18, 1968
Docket16611, 16612
StatusPublished
Cited by57 cases

This text of 397 F.2d 443 (Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United States, 397 F.2d 443 (7th Cir. 1968).

Opinion

HASTINGS, Circuit Judge.

Appellant, for himself and as executor of the estate of his deceased wife, appeals from adverse judgments entered October 6, 1967 in the district court on their actions for refunds of federal gift taxes. 1

The facts, most of which were stipulated, are undisputed. On July 6, 1961 taxpayers executed a trust agreement creating a trust for their twelve minor grandchildren. The trust res was a parcel of real estate valued at $132,500 and subject to a $82,500 mortgage. The grandchildren received equal shares. By the terms of the agreement the corpus was to vest as each beneficiary reached twenty-one years of age, and income was to be distributed at least annually to the beneficiaries. The trustee was given broad powers to deal with the trust property.

Taxpayers presented evidence that some months prior to the execution of the trust agreement they met with their accountant, their lawyer and a son who acted as their financial advisor to discuss creation of the trust. A tentative draft agreement was prepared incorporating taxpayers’ initial ideas. Taxpayers were informed by their advisors, however, that modifications would be necessary if the gifts in trust were to qualify for the annual gift tax exclusion pursuant to Title 26 U.S.C.A. § 2503(c). 2 Taxpayers agreed and instructed their attorney to conform the draft agreement to § 2503(c). Through inadvertence the draft agreement signed July 6, 1961 did not empower the trustee to invade corpus to meet the needs of the beneficiaries and did not allow the beneficiaries to dispose of their interests by will. The gifts therefore did not qualify under § 2503(c).

The trial court made no findings on the issue of mistake.

In gift tax returns filed April 14, 1962, taxpayers reported each of the twelve gifts as split gifts, 3 both taxpayers claiming an exclusion as to each gift. Since the total exclusion exceeded the $50,000 aggregate value of the gifts, no taxable gifts were reported.

*445 On September 10, 1963, taxpayers were notified by the District Director of Internal Revenue that the exclusions were to be disallowed because the gifts did not qualify under § 2503(c). Shortly thereafter taxpayers executed a Corrected Trust Agreement which purports to bring the July 6, 1961 agreement into conformity with § 2503(c). The corrected agreement was executed “as of July 6, 1961.”

On July 31, 1964 deficiencies of $4,-968.51 and $4,653.51 were assessed against taxpayers. These assessments were paid with interest on August 10, 1964 and timely claims for refund were filed. The claims were disallowed and these actions were brought to recover the taxes paid.

The principal issue raised is whether the amended trust agreement executed by taxpayers in 1963 retroactively determines the federal gift tax consequences of the 1961 gift in trust. Even assuming that the amended agreement expressed taxpayers’ intent at the time they executed the original agreement and that the discrepancy in that original agreement was caused by inadvertence, we hold the tax consequences must be determined by the original agreement.

Taxpayers cite several Wisconsin state cases for the proposition that a written instrument which, through mistake, does not embody the intent of the parties may be reformed by the parties through voluntary execution of a corrected instrument. However, not even judicial reformation can operate to change the federal tax consequences of a completed transaction. Straight’s Trust v. Commissioner of Internal Revenue, 8 Cir., 245 F.2d 327 (1957); Van Vlaanderen v. Commissioner of Internal Revenue, 3 Cir., 175 F.2d 389 (1949); Daine v. Commissioner of Internal Revenue, 2 Cir., 168 F.2d 449, 4 A.L.R.2d 248 (1948); Sinopoulo v. Jones, 10 Cir., 154 F.2d 648 (1946); cf. Commissioner of Internal Revenue v. Estate of Bosch, 2 Cir., 363 F.2d 1009, 1015 (1966) (dissenting opinion), rev’d., 387 U.S. 456, 87 S.Ct. 1776, 18 L.Ed.2d 886 (1967); Emerson Institute v. United States, 123 U.S.App.D.C. 71, 356 F.2d 824, cert, denied, 385 U.S. 822, 87 S.Ct. 49, 17 L.Ed. 2d 59 (1966). Contra, Flitcroft v. Commissioner of Internal Revenue, 9 Cir., 328 F.2d 449 (1964).

As to the parties to the reformed instrument the reformation relates back to the date of the original instrument, but it does not affect the rights acquired by non-parties, including the Government. Were the law otherwise there would exist considerable opportunity for “collusive” state court actions having the sole purpose of reducing federal tax liabilities. Furthermore, federal tax liablities would remain unsettled for years after their assessment if state courts and private persons were empowered to retroactively affect the tax consequences of completed transactions and completed tax years.

Taxpayers argue the distinction between mistake of fact, which they allege occurred here, and mistake of law, which they contend was involved in the cases cited in the Government’s brief. The mistake of fact-mistake of law dichotomy, developed in equity, is based on principles which have no application in determining the tax consequences of transactions subsequently reformed.

. The second issue raised by taxpayers is whether the gifts of income interests in the trust property are subject to the annual exclusion. The original trust agreement provided that the net income of the trust property be distributed to the beneficiaries annually or at shorter intervals. The Government concedes, as it must, that these were gifts of present interests. It contends, however, that they are not subject to the exclusion because their value was not ascertainable at the time the trust was created. The district court agreed.

To qualify for the annual exclusion the value of a gift of a present interest must be ascertainable at the time the gift is made. Commissioner of In *446 ternal Revenue v. Disston, 325 U.S. 442, 65 S.Ct. 1328, 89 L.Ed. 1720 (1945).

The trust agreement confers broad powers on the trustee to deal with the trust property. Among these are: the power to sell, exchange or alter the trust assets, the power to allocate receipts to principal or income, and the power to apportion expenditures to principal or income. A similar trust agreement was held not to permit ascertainment of the value of an income interest in Fischer v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Carlson v. Sweeney, Dabagia, Donoghue, Thorne, Janes & Pagos
868 N.E.2d 4 (Indiana Court of Appeals, 2007)
Greene v. United States
Federal Circuit, 2006
Estate of Starkey v. United States
58 F. Supp. 2d 939 (S.D. Indiana, 1999)
Estate of Simpson v. Commissioner
1994 T.C. Memo. 259 (U.S. Tax Court, 1994)
Estate of Bennett v. Commissioner
100 T.C. No. 5 (U.S. Tax Court, 1993)
Estate of La Meres v. Comm'r
98 T.C. No. 24 (U.S. Tax Court, 1992)
Estate of Nicholson v. Commissioner
94 T.C. No. 39 (U.S. Tax Court, 1990)
Meister v. Commissioner
1988 T.C. Memo. 487 (U.S. Tax Court, 1988)
Estate of Kraus v. Commissioner
1988 T.C. Memo. 154 (U.S. Tax Court, 1988)
Beck v. Commissioner
1987 T.C. Memo. 359 (U.S. Tax Court, 1987)
Ward v. Commissioner
87 T.C. No. 6 (U.S. Tax Court, 1986)
Pfluger v. Commissioner
1986 T.C. Memo. 78 (U.S. Tax Court, 1986)
Fono v. Commissioner
79 T.C. No. 44 (U.S. Tax Court, 1982)
Smith v. Commissioner
1981 T.C. Memo. 371 (U.S. Tax Court, 1981)
American Nurseryman Publishing Co. v. Commissioner
75 T.C. 271 (U.S. Tax Court, 1980)
LE Myers Co. v. Harbor Insurance Co.
384 N.E.2d 1340 (Appellate Court of Illinois, 1978)
Brent v. Commissioner
70 T.C. 775 (U.S. Tax Court, 1978)
Swetland v. Commissioner
1978 T.C. Memo. 47 (U.S. Tax Court, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
397 F.2d 443, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arnold-van-den-wymelenberg-as-of-the-estate-of-eleanor-van-den-ca7-1968.