Critchfield v. Commissioner
United States Tax Court
1. Held, under section 811(j), 1939 Code, the value at which shares of stock must be included in gross estate is their fair market value at the optional valuation date, rather than a lesser value based upon the amount per share for which decedent's widow was allowed to purchase the shares by a Probate Court in Ohio upon her election to purchase such property under section 10509-89, Ohio General Code. 2. Held, a marital deduction is not allowable under section 812(e) for an…
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1. Held, under section 811(j), 1939 Code, the value at which shares of stock must be included in gross estate is their fair market value at the optional valuation date, rather than a lesser value based upon the amount per share for which decedent's widow was allowed to purchase the shares by a Probate Court in Ohio upon her election to purchase such property under section 10509-89, Ohio General Code. 2. Held, a marital deduction is not allowable under section 812(e) for an alleged interest in property, represented by the difference between the probate appraisers' valuation of shares of stock…
1Opinion of the Court
Estate of Walter O. Critchfield, Deceased, Central National Bank of Cleveland, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Critchfield v. Commissioner
Docket No. 57975
United States Tax Court
32 T.C. 844; 1959 U.S. Tax Ct. LEXIS 134;
June 30, 1959, Filed
Decision will be entered for the respondent.
1. Held, under section 811(j), 1939 Code, the value at which shares of stock must be included in gross estate is their fair market value at the optional valuation date, rather than a lesser value based upon the amount per share for which decedent's widow was allowed to purchase…
2Cases cited10 opinions
- Helvering v. WinmillSupreme Court of the United States · 1938
- Hoffman v. CommissionerUnited States Tax Court · 1943
- Estate of Arthur Sweet, Deceased. Tracy-Collins Trust Company, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1956
- Giannini v. CommissionerCourt of Appeals for the Ninth Circuit · 1945
- Estate of Rainger v. CommissionerUnited States Tax Court · 1949
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