Steinberg v. Comm'r
United States Tax Court
P entered into a binding gift agreement with her daughters under which P gave her daughters properties and in exchange the daughters agreed to assume and to pay, among other things, any estate tax liability imposed under I.R.C. sec. 2035(b) as a result of the gifts in the event that P passed away within three years of the gifts.
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P entered into a binding gift agreement with her daughters under which P gave her daughters properties and in exchange the daughters agreed to assume and to pay, among other things, any estate tax liability imposed under I.R.C. sec. 2035(b) as a result of the gifts in the event that P passed away within three years of the gifts. In calculating for gift tax purposes the gross fair market value of the property transferred to the daughters, P reduced the fair market value of the properties by an amount representing the value of the daughters' assumption of the I.R.C. sec. 2035(b) estate tax…
1Opinion of the Court
JEAN STEINBERG, DONOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Steinberg v. Comm'r
Docket No. 23865-11.
United States Tax Court
145 T.C. 184; 2015 U.S. Tax Ct. LEXIS 40; 145 T.C. No. 7;
September 16, 2015, Filed
Steinberg v. Comm'r, 141 T.C. 258, 2013 U.S. Tax Ct. LEXIS 39 (2013)
Decision will be entered for petitioner.
P entered into a binding gift agreement with her daughters under which P gave her daughters properties and in exchange the daughters agreed to assume and to pay, among other things, any estate tax liability imposed under I.R.C. sec. 2035(b) as a result of the gifts…
2Cases cited36 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Loretto v. Teleprompter Manhattan CATV Corp.Supreme Court of the United States · 1982
- Bull v. United StatesSupreme Court of the United States · 1935
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
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