Security First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Order of a probate court of California fixing inheritance tax held not final and conclusive as to extent of property or interest passing to petitioner's decedent under the will of her mother. 2. Several writings constituting the will of the mother of petitioner's decedent construed as giving to decedent a life estate in a portion of the income of her mother's estate. 3. Where respondent claims as a basis for an increased deficiency that his determination of the value of…
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1. Order of a probate court of California fixing inheritance tax held not final and conclusive as to extent of property or interest passing to petitioner's decedent under the will of her mother. 2. Several writings constituting the will of the mother of petitioner's decedent construed as giving to decedent a life estate in a portion of the income of her mother's estate. 3. Where respondent claims as a basis for an increased deficiency that his determination of the value of realty was erroneous, the burden rests upon him to prove that he erred in his original determination.
1Opinion of the Court
SECURITY FIRST NATIONAL BANK OF LOS ANGELES, AS EXECUTOR OF THE ESTATE OF MARY S. MASON, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Security First Nat'l Bank v. Commissioner
Docket No. 84133.
United States Board of Tax Appeals
38 B.T.A. 425; 1938 BTA LEXIS 870;
August 30, 1938, Promulgated
1. Order of a probate court of California fixing inheritance tax held not final and conclusive as to extent of property or interest passing to petitioner's decedent under the will of her mother.
2. Several writings constituting the will of the mother of petitioner's decedent construed…
2Cases cited1 opinion
- Security First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1938