Estate of Watson v. Commissioner
United States Tax Court
Held, where a trust failed to provide for the disposition of the trust corpus after the termination of the trust, a beneficial interest in the trust corpus reverted to the settlor of the trust when the trust terminated and was included in his gross estate under sec. 2033. Held, further, the widow's allowance paid under Mississippi law to the decedent's widow qualifies for the marital deduction provided in sec. 2056(a). Held, further, respondent failed to meet his burden of…
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Held, where a trust failed to provide for the disposition of the trust corpus after the termination of the trust, a beneficial interest in the trust corpus reverted to the settlor of the trust when the trust terminated and was included in his gross estate under sec. 2033. Held, further, the widow's allowance paid under Mississippi law to the decedent's widow qualifies for the marital deduction provided in sec. 2056(a). Held, further, respondent failed to meet his burden of proving that rental proceeds from the decedent's farmland were improperly omitted from the gross estate on the decedent's…
1Opinion of the Court
HAMBLEN, Judge:
Respondent determined a deficiency of $437,231 in the Federal estate tax liability of the estate of Henri P. Watson. After trial, respondent amended his answer to conform the pleadings to the proof. In his amended answer, respondent asserted that the correct deficiency in petitioner’s estate tax is $470,370.72. After concessions, the issues remaining to be decided are: (1) Whether the full value of 1,073.18 acres of farmland located in Sunflower County, Mississippi, is included in the decedent’s gross estate; (2) whether the widow’s allowance paid to the decedent’s surviving…
2Cases cited29 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Jackson v. United StatesSupreme Court of the United States · 1964
- Ward v. CommissionerUnited States Tax Court · 1986
- Thomas v. BaileyMississippi Supreme Court · 1979
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3Cited by4 opinions
- Estate of Jalkut v. CommissionerUnited States Tax Court · 1991
- United States v. JohnsonDistrict Court, D. Utah · 2016
- Estate of Jalkut v. CommissionerUnited States Tax Court · 1991
- Estate of Watson v. CommissionerUnited States Tax Court · 1990