Legal Opinion

Estate of Cavett v. Commissioner

United States Tax Court

Decided March 15, 2000No. 21702-96, 21735-96UnpublishedCited by 2 opinions

R determined deficiencies in both estate and gift taxes. Ps claim overpayments of estate tax. We must determine whether (1) Ps are estopped from denying that certain inter vivos payments to decedent's longtime companion were gifts, (2) assuming there is no estoppel, the payments were gifts or payments for services, (3) a bequest to that companion is a deductible claim against the estate, (4) only one-half the value of decedent's residence is includable in the gross estate,…

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R determined deficiencies in both estate and gift taxes. Ps claim overpayments of estate tax. We must determine whether (1) Ps are estopped from denying that certain inter vivos payments to decedent's longtime companion were gifts, (2) assuming there is no estoppel, the payments were gifts or payments for services, (3) a bequest to that companion is a deductible claim against the estate, (4) only one-half the value of decedent's residence is includable in the gross estate, and (5) certain bequests to Masonic and fraternal organizations are deductible for estate tax purposes. 1. HELD: Ps are…

1Opinion of the Court

ESTATE OF LLOYD P. CAVETT, DECEASED, LLOYD PETERSON AND KYLE C. BROOKS, CO-EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Cavett v. Commissioner

No. 21702-96, 21735-96

United States Tax Court

T.C. Memo 2000-91; 2000 Tax Ct. Memo LEXIS 105; 79 T.C.M. (CCH) 1662;

March 15, 2000, Filed

Decisions will be entered under Rule 155.

R determined deficiencies in both estate and gift

taxes. Ps claim overpayments of estate tax. We must

determine whether (1) Ps are estopped from denying that

certain inter vivos payments to decedent's longtime

companion were gifts, (2) assuming there…

2Cases cited13 opinions

  1. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  2. Montana v. United StatesSupreme Court of the United States · 1979
  3. Commissioner v. DubersteinSupreme Court of the United States · 1960
  4. Clark v. Bear Stearns & Co.Court of Appeals for the Ninth Circuit · 1992
  5. United States v. Itt Rayonier, IncorporatedCourt of Appeals for the Ninth Circuit · 1980

8 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Estate of Shapiro v. United StatesCourt of Appeals for the Ninth Circuit · 2011
  2. Estate of Shapiro v. United StatesCourt of Appeals for the Ninth Circuit · 2011

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