Estate of Spruill v. Commissioner
United States Tax Court
In 1931, Stephen Spruill (Stephen), decedent's father, executed a deed conveying successive life estates in the Ashford-Dunwoody Farm to decedent and his wife (Georgia). Upon the termination of these life estates, the property was to go to decedent's children or to the descendants of any of decedent's children who did not survive the life estates; should decedent die without descendants, the property was to revert back to Stephen's estate.
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In 1931, Stephen Spruill (Stephen), decedent's father, executed a deed conveying successive life estates in the Ashford-Dunwoody Farm to decedent and his wife (Georgia). Upon the termination of these life estates, the property was to go to decedent's children or to the descendants of any of decedent's children who did not survive the life estates; should decedent die without descendants, the property was to revert back to Stephen's estate. In 1956, Stephen, Georgia, and decedent's two adult children (Weyman and Kathleen) executed quitclaim deeds to decedent of their interests in the…
1Opinion of the Court
FEATHERSTON, Judge;
Respondent determined a deficiency in the amount of $13,570,174.98 in the estate tax for the Estate of Euil S. Spruill and an addition to tax under section 6653(b)2 in the amount of $6,785,087.49. Also, respondent determined deficiencies in the individual petitioners’ 1981 Federal income taxes as follows:
Petitioner , Deficiency
Weyman E. and Jennie Spruill.$2,600,815.56
Lewis J. Miers, Jr., and Kathleen S. Miers. 2,616,954.34
The issues for decision are:(1) Whether the Ashford-Dunwoody Farm (exclusive of two homesites thereon) is includable in decedent’s gross estate under…
2Cases cited54 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- United States v. BoyleSupreme Court of the United States · 1985
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Gajewski v. CommissionerUnited States Tax Court · 1976
49 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
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- Estate of Kahn v. Comm'rUnited States Tax Court · 2005
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