Northport Shores v. Commissioner
United States Board of Tax Appeals
1. ESTOPPEL. - Where respondent does not affirmatively establish his reliance on taxpayer's representation or misrepresentation of fair market value of devised real estate, in determining that value as the basis for estate tax, equitable estoppel is not established and taxpayer may prove that value in a proceeding here, involving deficiencies in and overpayments of income taxes arising upon a conveyance of such real estate by the devisee. 2. Fair market value of real estate…
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1. ESTOPPEL. - Where respondent does not affirmatively establish his reliance on taxpayer's representation or misrepresentation of fair market value of devised real estate, in determining that value as the basis for estate tax, equitable estoppel is not established and taxpayer may prove that value in a proceeding here, involving deficiencies in and overpayments of income taxes arising upon a conveyance of such real estate by the devisee. 2. Fair market value of real estate determined.
1Opinion of the Court
OPINION.
Leech:
These consolidated proceedings involve deficiencies in income tax, and alleged overpayment of such taxes for the calendar year 1929, as follows:
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*1014The issues framed by the pleadings have been limited by petitioners’ withdrawal of assignments of error to (1) the amount received by petitioner, Martha M. Hall, in 1929 on retirement of certain shares of the capital stock of petitioner, Northport Shores, Inc., and (2) -the cost basis to petitioners of certain property, hereinafter sometimes called the Hall property, exchanged by petitioner, Martha M. Hall, in 1927 for all…
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