Legal Opinion

Estate of Heckscher v. Commissioner

United States Tax Court

Decided January 29, 1975No. Docket No. 6896-72Published

Held, value of shares of stock of a closely held investment company which represented a small minority interest in the company, determined.

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Held, value of shares of stock of a closely held investment company which represented a small minority interest in the company, determined. Held, further, attorney's fees paid directly by a beneficiary of a trust, the value of which was includable in decedent's gross estate by virtue of his exercise by will of a general power of appointment with respect thereto, for services rendered in an action brought by the trustee for instructions as to distribution of the trust estate, are not deductible by the estate of decedent as administration expenses under sec. 2053(b), I.R.C. 1954.

1Opinion of the Court

Estate of Maurice Gustave Heckscher, Leo R. Best, Administrator, c.t.a., Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Heckscher v. Commissioner

Docket No. 6896-72

United States Tax Court

63 T.C. 485; 1975 U.S. Tax Ct. LEXIS 199;

January 29, 1975, Filed

Decision will be entered under Rule 155.

Held, value of shares of stock of a closely held investment company which represented a small minority interest in the company, determined. Held, further, attorney's fees paid directly by a beneficiary of a trust, the value of which was includable in decedent's gross estate by virtue of…

2Cases cited13 opinions

  1. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  2. Messing v. CommissionerUnited States Tax Court · 1967
  3. Mosells Silvey Pitner v. United StatesCourt of Appeals for the Fifth Circuit · 1967
  4. Estate of Heckscher v. CommissionerUnited States Tax Court · 1975
  5. Burrow Trust v. CommissionerUnited States Tax Court · 1963

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