Legal Opinion

Hurlbut v. Commissioner

United States Board of Tax Appeals

Decided December 31, 1935No. Docket Nos. 71788, 75494Published

Where the respondent fails to show that property of an ancestor received by heirs has any value above encumbrances, there is no transferee liability of the heirs.

1Opinion of the Court

E. M. HURLBUT, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

GLADYS G. LAWRENCE, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hurlbut v. Commissioner

Docket Nos. 71788, 75494.

United States Board of Tax Appeals

33 B.T.A. 868; 1935 BTA LEXIS 700;

December 31, 1935, Promulgated

Where the respondent fails to show that property of an ancestor received by heirs has any value above encumbrances, there is no transferee liability of the heirs.

Sam H. Benbow, Esq., for the petitioners.

Willis R. Lansford, Esq., for the respondent.

SEAWELL

Transferee…

2Cases cited2 opinions

  1. Ashton v. CommissionerUnited States Board of Tax Appeals · 1933
  2. Hurlbut v. CommissionerUnited States Board of Tax Appeals · 1935

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