Wood v. Commissioner
United States Board of Tax Appeals
1. The decedent established a trust, the corpus of which was shares of stock in two companies. Some of the shares were at the time pledged as collateral for loans made to decedent by a number of banks.
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1. The decedent established a trust, the corpus of which was shares of stock in two companies. Some of the shares were at the time pledged as collateral for loans made to decedent by a number of banks. The trust instrument provided that the income from the corpus of the trust should first be used to discharge such bank loans and certain unsecured obligations for which the decedent was personally liable, and should decedent during should his lifetime liquidate said indebtedness or after his death should his estate pay said debts, the income of the trust should be used to reimburse either…
1Opinion of the Court
*537OPINION.
Aeundell :
Section 303 (a) (1) of the 1924 Act, which is the applicable taxing statute, provides that in determining the value of the net estate there'shall be allowed as a deduction from the value of the gross estate such amounts for “ claims against the estate ” to the extent that they “ were incurred or contracted bona fide and for an adequate and full consideration in money or money’s worth * * * as are allowed by the laws of the jurisdiction * * Our first consideration then is to determine whether the sum of $381,813.77 sought to be deducted constitutes “ claims against the…
2Cases cited7 opinions
- Fox v. DunningSupreme Court of Oklahoma · 1927
- Grand Council of Pennsylvania Royal Arcanum v. CorneliusSupreme Court of Pennsylvania · 1901
- Tubbs's EstateSupreme Court of Pennsylvania · 1894
- Underwood v. Metropolitan National BankSupreme Court of the United States · 1892
- State Nat. Bank of Denison v. Syndicate Co. of Eureka SpringsU.S. Circuit Court for the District of Western Arkansas · 1910
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Estate of Frederick C. Hodgdon v. CommissionerUnited States Tax Court · 1952
- Wood v. CommissionerUnited States Board of Tax Appeals · 1932