Legal Opinion

Estate of Boyd v. Commissioner

United States Tax Court

Decided December 30, 1985No. Docket No. 30219-82Published

Decedent's gross estate consisted of probate and nonprobate assets. The nonprobate assets included life insurance proceeds on decedent's life, payable to decedent's son. Decedent's will directed the estate's representatives to pay all Federal estate and State inheritance taxes imposed upon the gross estate, including tax imposed upon nonprobate property. Decedent's son, the sole beneficiary under the will, disclaimed his testate and intestate interests.

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Decedent's gross estate consisted of probate and nonprobate assets. The nonprobate assets included life insurance proceeds on decedent's life, payable to decedent's son. Decedent's will directed the estate's representatives to pay all Federal estate and State inheritance taxes imposed upon the gross estate, including tax imposed upon nonprobate property. Decedent's son, the sole beneficiary under the will, disclaimed his testate and intestate interests. The net probate estate passed by intestacy to decedent's surviving spouse and qualified for a marital deduction. Held: Decedent's son, the…

1Opinion of the Court

Estate of Edward A. Boyd, Julia H. Boyd and Michael E. Boyd, Co-Personal Representatives, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Boyd v. Commissioner

Docket No. 30219-82

United States Tax Court

85 T.C. 1056; 1985 U.S. Tax Ct. LEXIS 2; 85 T.C. No. 61;

December 30, 1985, Filed

Decision will be entered under Rule 155.

Decedent's gross estate consisted of probate and nonprobate assets. The nonprobate assets included life insurance proceeds on decedent's life, payable to decedent's son. Decedent's will directed the estate's representatives to pay all Federal estate and State…

2Cases cited19 opinions

  1. Riggs v. Del DragoSupreme Court of the United States · 1942
  2. Nunnemacher v. StateWisconsin Supreme Court · 1906
  3. Uihlein v. UihleinWisconsin Supreme Court · 1953
  4. Estate of StephensonWisconsin Supreme Court · 1920
  5. Adele H. Dodd and William A. Dodd, Executors of the Estate of John A. Dodd, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1965

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