Estate of Satz v. Commissioner
United States Tax Court
Decedent's former wife, Ruth, brought an action and obtained a judgment against decedent's estate for his failure to name her the beneficiary of certain life insurance policies. Her claim was premised on a separation agreement executed by Ruth and decedent which was incorporated into a divorce decree. Petitioner claims a deduction of $ 66,675.48 under sec. 2053, I.R.C. 1954, for funds paid to Ruth pursuant to the judgment.
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Decedent's former wife, Ruth, brought an action and obtained a judgment against decedent's estate for his failure to name her the beneficiary of certain life insurance policies. Her claim was premised on a separation agreement executed by Ruth and decedent which was incorporated into a divorce decree. Petitioner claims a deduction of $ 66,675.48 under sec. 2053, I.R.C. 1954, for funds paid to Ruth pursuant to the judgment. Held, petitioner is not entitled to a deduction under sec. 2053 merely because State law may have provided that the separation agreement operated as an equitable assignment…
1Opinion of the Court
OPINION
Tannenwald, Chief Judge:
Respondent determined a deficiency of $18,486.66 in petitioner’s Federal estate taxes. We must determine whether petitioner is entitled to a deduction of $66,675.48 under section 20531 for amounts paid to decadent’s former wife because of decedent’s failure to name her the beneficiary of certain life insurance policies.2
This case was submitted fully stipulated pursuant to Rule 122. The stipulation of facts is incorporated by this reference.
Petitioner is the Estate of Edward Satz represented by its executor, Robert S. Goldenhersh (Mr. Goldenhersh). At the time he…
2Cases cited36 opinions
- Merrill v. FahsSupreme Court of the United States · 1945
- Harris v. CommissionerSupreme Court of the United States · 1950
- North v. NorthSupreme Court of Missouri · 1936
- Gardine v. CotteySupreme Court of Missouri · 1950
- Niederkorn v. NiederkornMissouri Court of Appeals · 1981
31 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Estate of Smith v. CommissionerUnited States Tax Court · 1990
- Estate of Elizabeth G. Huntington, Deceased, Nancy H. Brunson, Administratrix v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1994
- Daniel S. Natchez and Peter Natchez, Executors of the Estate of Benjamin H. Natchez v. United StatesCourt of Appeals for the Second Circuit · 1983
- Estate of Satz v. CommissionerUnited States Tax Court · 1982
- Estate of Smith v. CommissionerUnited States Tax Court · 1990
2 more not listed; retrieve them via the Exa API.