Legal Opinion

Estate of Friedberg v. Commissioner

United States Tax Court

Decided June 1, 1992No. Docket No. 2015-89UnpublishedCited by 3 opinions

Decedent owned shares in Fair Lanes, Inc. Certain of those shares were subject to a redemption agreement between decedent and Fair Lanes, Inc. Decedent transferred, within 3 years of death, certain life insurance policies to his daughter, who is named by his will as his personal representative. Decedent's will also provided for a $ 500,000 payment to decedent's wife, and provided that such bequest might, under certain circumstances, be delayed for up to 5 years.

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Decedent owned shares in Fair Lanes, Inc. Certain of those shares were subject to a redemption agreement between decedent and Fair Lanes, Inc. Decedent transferred, within 3 years of death, certain life insurance policies to his daughter, who is named by his will as his personal representative. Decedent's will also provided for a $ 500,000 payment to decedent's wife, and provided that such bequest might, under certain circumstances, be delayed for up to 5 years. In that event, the bequest was to bear interest according to a formula set forth in decedent's will. On the estate tax return,…

1Opinion of the Court

ESTATE OF SIDNEY M. FRIEDBERG, DECEASED, DAVID P. GORDON AND LAURA RACHEL BURROWS, PERSONAL REPRESENTATIVES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Friedberg v. Commissioner

Docket No. 2015-89

United States Tax Court

T.C. Memo 1992-310; 1992 Tax Ct. Memo LEXIS 330; 63 T.C.M. (CCH) 3080;

June 1, 1992, Filed

Decision will be entered under Rule 155.

Decedent owned shares in Fair Lanes, Inc. Certain of those shares were subject to a redemption agreement between decedent and Fair Lanes, Inc. Decedent transferred, within 3 years of death, certain life insurance policies to…

2Cases cited18 opinions

  1. Bull v. United StatesSupreme Court of the United States · 1935
  2. United States v. DalmSupreme Court of the United States · 1990
  3. United States v. CartwrightSupreme Court of the United States · 1973
  4. Messing v. CommissionerUnited States Tax Court · 1967
  5. Swanson v. CommissionerSupreme Court of the United States · 1935

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

3Cited by3 opinions

  1. Leon S. Malachinski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
  2. Leon S. Malachinski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
  3. Malachinski, Leon S. v. CIRCourt of Appeals for the Seventh Circuit · 2001

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