Hahn v. Comm'r
United States Tax Court
P and her husband (H) purchased property in 1972 as joint tenants with right of survivorship. P became the sole owner of the property upon H's death in 1991. H's Federal Estate Tax Return reported 100 percent of the date of death value of the property as H's interest therein. P sold the property in 1993 and, pursuant to secs. 2040(a) and 1014(b)(9), I.R.C., included 100 percent of the date of death value of the property in calculating her basis.
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P and her husband (H) purchased property in 1972 as joint tenants with right of survivorship. P became the sole owner of the property upon H's death in 1991. H's Federal Estate Tax Return reported 100 percent of the date of death value of the property as H's interest therein. P sold the property in 1993 and, pursuant to secs. 2040(a) and 1014(b)(9), I.R.C., included 100 percent of the date of death value of the property in calculating her basis. R determined that, because H died after Dec. 31, 1981, pursuant to sec. 2040(b)(1), I.R.C., only 50 percent of the date of death value of the…
1Opinion of the Court
THERESE HAHN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hahn v. Comm'r
Tax Ct. Dkt. No. 17210-96
United States Tax Court
110 T.C. 140; 1998 U.S. Tax Ct. LEXIS 13; 110 T.C. No. 14;
March 4, 1998, Filed
The court denied the taxpayer's motion for summary judgment and the motion for partial summary judgment by the IRS.
P and her husband (H) purchased property in 1972 as joint tenants with right of survivorship. P became the sole owner of the property upon H's death in 1991. H's Federal Estate Tax Return reported 100 percent of the date of death value of the property as H's interest…
2Cases cited20 opinions
- United States v. Diebold, Inc.Supreme Court of the United States · 1962
- West Virginia University Hospitals, Inc. v. CaseySupreme Court of the United States · 1991
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Barnhill v. JohnsonSupreme Court of the United States · 1992
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