Miller v. Commissioner
United States Tax Court
At the time of his death, decedent and his wife owned all of the stock in two corporations to which decedent was indebted in the amounts of $ 30,000 and $ 3,000. Pursuant to an order of the Probate Court, the last day for filing claims against the estate was Feb. 21, 1973. The corporations did not file claims against the estate for these debts.
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At the time of his death, decedent and his wife owned all of the stock in two corporations to which decedent was indebted in the amounts of $ 30,000 and $ 3,000. Pursuant to an order of the Probate Court, the last day for filing claims against the estate was Feb. 21, 1973. The corporations did not file claims against the estate for these debts. Nevertheless, in Aug. 1973, the estate filed a Federal estate tax return on which it reported the indebtedness to the corporations by claiming a $ 33,000 deduction. Wisconsin law (Wis. Stat. Ann. secs. 859.01 and 859.05 (West 1971) provides that claims…
1Opinion of the Court
Carl T. Miller Trust, Alice G. Miller, Trustee, and Alice G. Miller, Petitioners v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket No. 10909-78
United States Tax Court
76 T.C. 191; 1981 U.S. Tax Ct. LEXIS 180;
February 2, 1981, Filed
Decision will be entered for the respondent.
At the time of his death, decedent and his wife owned all of the stock in two corporations to which decedent was indebted in the amounts of $ 30,000 and $ 3,000. Pursuant to an order of the Probate Court, the last day for filing claims against the estate was Feb. 21, 1973. The corporations did not…
2Cases cited31 opinions
- Campbell v. HoltSupreme Court of the United States · 1885
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Haase v. SawickiWisconsin Supreme Court · 1963
- Eingartner v. Illinois Steel Co.Wisconsin Supreme Court · 1899
- Johnson v. HeintzWisconsin Supreme Court · 1976
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