Estate of Papson v. Commissioner
United States Tax Court
Decedent died in 1973. A shopping center constituted more than 35 percent of his gross estate. Petitioner elected deferred payment under sec. 6166, I.R.C. 1954. In 1976, the primary tenant in the shopping center vacated the premises due to bankruptcy. The executor incurred a brokerage commission to obtain a new tenant. Held, the broker's commission qualifies as an administration expense under sec. 2053(a)(2), I.R.C. 1954.
1Opinion of the Court
Estate of Leonidas C. Papson, Deceased, Costa L. Papson, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Papson v. Commissioner
Docket No. 10249-76
United States Tax Court
73 T.C. 290; 1979 U.S. Tax Ct. LEXIS 21;
November 20, 1979, Filed
Decision will be entered under Rule 155.
Decedent died in 1973. A shopping center constituted more than 35 percent of his gross estate. Petitioner elected deferred payment under sec. 6166, I.R.C. 1954. In 1976, the primary tenant in the shopping center vacated the premises due to bankruptcy. The executor incurred a brokerage commission…
2Cases cited27 opinions
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- Blood v. . KaneNew York Court of Appeals · 1892
- Goodell v. KochSupreme Court of the United States · 1930
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
- Estate of David Smith, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
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