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The decedent made taxable gifts during life, but failed to pay the associated gift tax. Upon death, the estate did not pay the gift tax either. The IRS claimed that the donees of the gifts owed the gift tax and interest on the gifts. The donees argued that the interest on the gift tax was limited to the value of the gift to any particular done under I.R.C. Sec. 6324(b). The court agreed that the interest on the gift cannot exceed the amount of the gift. United States v. Marshall, No. 12-20804, 2015 U.S. App. LEXIS14584 (5th Cir. Aug. 19, 2015), aff'g in part and rev'g in part, In re Marshall, 721 F.3d 1032 (9th Cir. 2013) and withdrawing 771 F.3d 854 (5th Cir. 2014).