Estate of Lepoutre v. Commissioner
United States Tax Court
Decedent and her husband, while residents of France, entered into a valid antenuptial agreement electing, in accordance with French law, the marital system of community property and providing that in case of dissolution of the community by death of one of the spouses, the survivor shall have full ownership of one-half of the total community property and a life estate until remarriage (usufruct) in the remaining one-half.
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Decedent and her husband, while residents of France, entered into a valid antenuptial agreement electing, in accordance with French law, the marital system of community property and providing that in case of dissolution of the community by death of one of the spouses, the survivor shall have full ownership of one-half of the total community property and a life estate until remarriage (usufruct) in the remaining one-half. After acquiring substantial community property, the couple became residents and citizens of the United States. They were domiciled in Connecticut at the date of decedent's…
1Opinion of the Court
OPINION
Scott, Judge:
The Commissioner determined a deficiency in Federal estate tax of the Estate of Jeanne Lepoutre, deceased, in the amount of $84,295.54. Petitioner, the administrator of the estate, was a resident of Brooklyn, New York, at the time of the filing of the petition in this case. The estate tax return of Jeanne Lepoutre’s estate was filed with the district director of internal revenue, Hartford, Conn.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision:(1) "Whether one-half of the community property of decedent and…
2Cases cited15 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Poe v. SeabornSupreme Court of the United States · 1930
- May v. HeinerSupreme Court of the United States · 1930
- Klein v. United StatesSupreme Court of the United States · 1931
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3Cited by5 opinions
- Estate of Gamble v. CommissionerUnited States Tax Court · 1978
- Estate of Gibson v. CommissionerUnited States Tax Court · 1976
- Estate of Gamble v. CommissionerUnited States Tax Court · 1978
- Estate of Gibson v. CommissionerUnited States Tax Court · 1976
- Estate of Lepoutre v. CommissionerUnited States Tax Court · 1974