Estate of Wood v. Commissioner
United States Tax Court
1. Held, income taxes incurred subsequent to the death of the transferee decedent by another taxable entity do not reduce the value of the interest of the within decedent in the prior estate under sec. 2033, I.R.C. 1954; nor are they deductible from the within decedent's gross estate under sec. 2053(a)(3), I.R.C. 1954. 2. Held, further, administration expenses deducted from the estate's Federal income taxes pursuant to an election under sec. 642(g), I.R.C. 1954, are not…
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1. Held, income taxes incurred subsequent to the death of the transferee decedent by another taxable entity do not reduce the value of the interest of the within decedent in the prior estate under sec. 2033, I.R.C. 1954; nor are they deductible from the within decedent's gross estate under sec. 2053(a)(3), I.R.C. 1954. 2. Held, further, administration expenses deducted from the estate's Federal income taxes pursuant to an election under sec. 642(g), I.R.C. 1954, are not available to reduce the "taxable estate" of the transferor for purposes of the computation of the credit for tax on prior…
1Opinion of the Court
OPINION
Stbkkett, Judge:
The respondent determined a deficiency in the Federal estate tax of the Estate of Howard O. Wood, Jr., in the amount of $20,388.88. There are two questions presented for our decision. The first is whether the income tax liabilities of the Estate of Caryl Hackstaff Wood should be allowed as a deduction to reduce the value of the interest of the present decedent, Howard O. Wood, Jr., in t-lie prior estate. The second concerns the proper method of computing- tlie credit for tax oil prior transfers under section 2013 of the Internal Revenue Code of 1954.1 Specifically as to…
2Cases cited9 opinions
- Burrow Trust v. CommissionerUnited States Tax Court · 1963
- Commissioner of Internal Revenue v. DavisCourt of Appeals for the First Circuit · 1943
- Haggart's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
- Haggart v. CommissionerUnited States Tax Court · 1949
- Gilruth v. CommissionerUnited States Tax Court · 1968
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Estate of La Sala v. CommissionerUnited States Tax Court · 1979
- Estate of Whittle v. CommissionerUnited States Tax Court · 1991
- Estate of La Sala v. CommissionerUnited States Tax Court · 1979
- Estate of Whittle v. CommissionerUnited States Tax Court · 1991
- Estate of Wood v. CommissionerUnited States Tax Court · 1970