Pierce Estates, Inc. v. Commissioner
United States Tax Court
1. A Texas decedent died testate in 1900. In his will, which was probated early in 1901, he directed that his property be held in trust and that the trust continue for a certain specified time which ended in 1929. Held, the basis of petitioner Pierce Estates, Inc., for certain cattle which were sold or died during the taxable years was the same as it was in the hands of the transferors; held, further, the basis in the hands of the transferors was zero, because under the will…
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1. A Texas decedent died testate in 1900. In his will, which was probated early in 1901, he directed that his property be held in trust and that the trust continue for a certain specified time which ended in 1929. Held, the basis of petitioner Pierce Estates, Inc., for certain cattle which were sold or died during the taxable years was the same as it was in the hands of the transferors; held, further, the basis in the hands of the transferors was zero, because under the will it is held that although the decedent provided for an administration of his estate independent of the probate court,…
1Opinion of the Court
OPINION.
Black, Judge:
We shall consider the issues in the order previously stated.
Issue No. 1. — In its returns for the years 1938,1939, and 1940, petitioner Pierce Estates, Inc., claimed a basis for cattle which were either sold or which died during those years of $39,180, $45,220, and $41,140, respectively. These cattle had been acquired by petitioner at the time of its incorporation in 1929 from the four grandchildren of Abel H. Pierce, deceased, by the issuance of shares of stock to them. Petitioner concedes that the basis originally claimed was too high and now contends that the basis for…
2Cases cited13 opinions
- Helvering v. BlissSupreme Court of the United States · 1934
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
- Maguire v. CommissionerSupreme Court of the United States · 1941
- Heller v. CommissionerUnited States Tax Court · 1943
8 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Kasey v. CommissionerUnited States Tax Court · 1970
- Chick v. CommissionerUnited States Tax Court · 1946
- Farrier v. CommissionerUnited States Tax Court · 1950
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1962
- Tyler v. CommissionerUnited States Tax Court · 1946
17 more not listed; retrieve them via the Exa API.