Legal Opinion

Neuhoff v. Commissioner

United States Tax Court

Decided October 7, 1980No. Docket No. 9650-76Published

Petitioner and her husband purchased U.S. Treasury bonds (flower bonds) which were redeemable at their par value to the extent they were utilized to pay Federal estate tax. At the time the bonds were acquired, petitioner obtained a vested interest in one-half of the bonds under the community property law of Texas.

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Petitioner and her husband purchased U.S. Treasury bonds (flower bonds) which were redeemable at their par value to the extent they were utilized to pay Federal estate tax. At the time the bonds were acquired, petitioner obtained a vested interest in one-half of the bonds under the community property law of Texas. Following acquisition of the bonds, petitioner's husband died and one-half of the bonds were distributed to petitioner as her share of the community interest, while the remaining half was included in her husband's gross estate as his share of the community interest. To the extent…

1Opinion of the Court

Ann F. Neuhoff, Petitioner v. Commissioner of Internal Revenue, Respondent

Neuhoff v. Commissioner

Docket No. 9650-76

United States Tax Court

75 T.C. 36; 1980 U.S. Tax Ct. LEXIS 43;

October 7, 1980, Filed

Decision will be entered for the respondent.

Petitioner and her husband purchased U.S. Treasury bonds (flower bonds) which were redeemable at their par value to the extent they were utilized to pay Federal estate tax. At the time the bonds were acquired, petitioner obtained a vested interest in one-half of the bonds under the community property law of Texas. Following acquisition of the bonds,…

2Cases cited12 opinions

  1. R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
  2. Arnold v. LeonardTexas Supreme Court · 1925
  3. Hopkins v. BaconSupreme Court of the United States · 1930
  4. Bankers Trust Company, as of the Will of Harriet Delta Ellis, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1960
  5. Houghton v. CommissionerUnited States Tax Court · 1967

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