Citation Codes Equivalent Citations citation codes Docket Number No. 72-3232. Summary Calendar. Attorney(S) Hugh Anderson, John Russell Crews, Lubbock, Tex., for plaintiff-appellant. Frank D. McCown, U.S. Atty., William W. Guild, Tax Div., Dept. of Justice, Dallas, Tex., Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Atty., Tax. Div., Dept. of Justice, Washington, D.C., Eldon B. Mahon, U.S. Atty., Fort Worth, Tex., for defendant-appellee. Judges William Homer Thornberry James Plemon Coleman Joe McDonald Ingraham See more information ... Smart Summary Please sign up to generate summary. JUANELLE TUBBS, PLAINTIFF-APPELLANT, v. UNITED STATES OF AMERICA, DEFENDANT-APPELLEE. PER CURIAM: The facts in this estate tax refund suit are well summarized in the district court's opinion, 348 F. Supp. 1404. Those facts establish conclusively the existence of an implied agreement that the transferor was to have lifetime enjoyment of the property. Guynn v. United States, 4th Cir. 1971, 437 F.2d 1148. Thus, the value of the property was properly includible in the transferor's estate, and the district court properly directed a verdict in appellee's favor. Affirmed.