High Quality Content by WIKIPEDIA articles! Walton v. Commissioner, 115 T.C. 589 (2000), a decision of the United States Tax Court in favor of taxpayer Audrey J. Walton, "ruled that a grantor`s right to receive a fixed amount for a term of years, if that right is a qualified interest within the meaning of Section 2702(b), is valued for gift tax purposes under Section 7520, without regard to the life expectancy of the transferor." More simply, a grantor`s estate`s contingent interest in a grantor-created annuity upon the grantor`s death does not constitute a gift to anyone; but rather, is a retained interest of the grantor.