Legal Opinion

Jane W. Holbrook and First National Bank of Arizona, Co-Executors of the Estate of William Wraith, Jr., Deceased v. United States

Court of Appeals for the First Circuit

Decided June 1, 1978No. 76-3122PublishedCited by 10 opinions

1Opinion of the Court

ORRICK, District Judge:

The co-executors of the Estate of William Wraith, Jr. sued for a refund of federal estate taxes, claiming the Estate is entitled to a credit against tax under Section 2013 of the Internal Revenue Code of 1954, 26 U.S.C. § 2013, 1 which provides for a credit based on the value of property transferred to the decedent within ten years before his or her death, in a transfer which was itself subject to estate tax. Here the property transferred was a life income interest under a testamentary trust, the value of which is determined as of the transferor’s death. However, the…

2Cases cited18 opinions

  1. Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
  2. Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
  3. Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United StatesCourt of Appeals for the Seventh Circuit · 1968
  4. Estate of Lillie MacMunn Stewart, Deceased, W. Alan Henderson v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
  5. Greenport Basin & Construction Co. v. United StatesSupreme Court of the United States · 1923

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3Cited by10 opinions

  1. Alma M. O'Reilly v. Commissioner of Internal Revenue, Charles H. O'reilly, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
  2. Estate of Lloyd v. United StatesUnited States Court of Claims · 1981
  3. Estate of Marks v. CommissionerUnited States Tax Court · 1990
  4. Estate of Pollock v. CommissionerUnited States Tax Court · 1981
  5. Boryan v. United StatesDistrict Court, E.D. Virginia · 1988

5 more not listed; retrieve them via the Exa API.

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