Legal Opinion

Union Commerce Bank v. Commissioner

United States Tax Court

Decided March 22, 1963No. Docket No. 93381Published

1. Petitioner is a transferee of Ethel Baker Kolb who was a tranferee of her mother (decedent) Justina C. Baker. Ethel F. Kaufman, a widow and sister of decedent, died testate in 1939. In her will, except for a specific bequest of $ 1,000, she left all of her property in trust to pay two-thirds of the income in equal shares to her sister Justina, her niece Ethel Baker Kolb, her brother Leon D. Mowry, and her niece Mary Henrietta Mowry (daughter of Leon). The will was…

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1. Petitioner is a transferee of Ethel Baker Kolb who was a tranferee of her mother (decedent) Justina C. Baker. Ethel F. Kaufman, a widow and sister of decedent, died testate in 1939. In her will, except for a specific bequest of $ 1,000, she left all of her property in trust to pay two-thirds of the income in equal shares to her sister Justina, her niece Ethel Baker Kolb, her brother Leon D. Mowry, and her niece Mary Henrietta Mowry (daughter of Leon). The will was uncertain as to the disposition of the other one-third of the income and the remainder. The will was contested by the heirs of…

1Opinion of the Court

The Union Commerce Bank, Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent

Union Commerce Bank v. Commissioner

Docket No. 93381

United States Tax Court

39 T.C. 973; 1963 U.S. Tax Ct. LEXIS 173;

March 22, 1963, Filed

Decision will be entered under Rule 50.

1. Petitioner is a transferee of Ethel Baker Kolb who was a tranferee of her mother (decedent) Justina C. Baker. Ethel F. Kaufman, a widow and sister of decedent, died testate in 1939. In her will, except for a specific bequest of $ 1,000, she left all of her property in trust to pay two-thirds of the income in equal shares to…

2Cases cited9 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Lyeth v. HoeySupreme Court of the United States · 1938
  3. Hornor's Estate v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Third Circuit · 1942
  4. Hornor v. CommissionerUnited States Board of Tax Appeals · 1941
  5. Commissioner of Internal Revenue v. Estate of Elizabeth W. Vease, Deceased, James L. VeaseCourt of Appeals for the Ninth Circuit · 1963

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