Gade v. Commissioner
United States Tax Court
Money of decedent held by bank in agency account "subject to owner's instructions," held excluded from gross estate as "moneys deposited," within the meaning of Internal Revenue Code, section 863 (b).
1Opinion of the Court
OPINION.
Opper, Judge-.
In this proceeding respondent determined a deficiency of $8,110.87 in estate tax of the estate of F. Herman Gade, hereinafter referred to as decedent. A claim for an increased deficiency has been made by respondent, to be adjusted in the computation under Bule 50.
A question as to the fair market value of decedent’s interests in certain realty having been settled by stipulation, the sole remaining issue is whether funds of decedent held by a Chicago bank under an agency agreement are excluded from decedent’s gross estate as “moneys deposited * * * by or for” decedent with…
2Cases cited3 opinions
- Oulton v. Savings InstitutionSupreme Court of the United States · 1873
- Weiss v. CommissionerUnited States Tax Court · 1946
- Estate of Davey v. CommissionerUnited States Tax Court · 1948
3Cited by17 opinions
- De Eissengarthen v. CommissionerUnited States Tax Court · 1948
- Oei Tjong Swan v. CommissionerUnited States Tax Court · 1955
- Bradford-Martin v. CommissionerUnited States Tax Court · 1952
- Estate of Oei Tjong Swan, Oei Ing Tjhing v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Estate of Loewenstein v. CommissionerUnited States Tax Court · 1951
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