Legal Opinion

Estate of Owen v. Commissioner

United States Tax Court

Decided April 20, 1995No. Docket No. 13004-90Published

Decedent died on Oct. 2, 1986. Decedent made gifts in 1984 and before death in 1986. Petitioner paid Kansas State inheritance tax on account of substantially all of these gifts. After decedent's death, there were found in his car checks that had been written by him during the 2 weeks before his death.

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Decedent died on Oct. 2, 1986. Decedent made gifts in 1984 and before death in 1986. Petitioner paid Kansas State inheritance tax on account of substantially all of these gifts. After decedent's death, there were found in his car checks that had been written by him during the 2 weeks before his death. Petitioner underreported the value of two bank accounts on its Federal estate tax return by the amount of these checks. 1. Held, the underreporting of the value of a bank account can be a valuation understatement within the meaning of sec. 6660, I.R.C. 1954. 2. Held, further, petitioner is not…

1Opinion of the Court

Estate of Jack Brown Owen, Deceased, Mary Ann Heyen, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Owen v. Commissioner

Docket No. 13004-90

United States Tax Court

104 T.C. 498; 1995 U.S. Tax Ct. LEXIS 25; 104 T.C. No. 25;

April 20, 1995, Filed

Decision will be entered under Rule 155.

Decedent died on Oct. 2, 1986. Decedent made gifts in 1984 and before death in 1986. Petitioner paid Kansas State inheritance tax on account of substantially all of these gifts. After decedent's death, there were found in his car checks that had been written by him during the 2 weeks…

2Cases cited21 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  3. Pallottini v. CommissionerUnited States Tax Court · 1988
  4. Commissioner v. Keystone Consolidated Industries, Inc.Supreme Court of the United States · 1993
  5. United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955

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