Estate of Hoover v. Commissioner
United States Tax Court
The decedent, Mrs. Clara K. Hoover, through a revocable trust, held a 26-percent interest in a limited partnership that owned and operated a large ranch. The fair market value of the real estate component of the assets of the limited partnership was eligible, in accordance with sec. 2032A(g), I.R.C., to be replaced by a lower "value" for purposes of inclusion of Mrs. Hoover's 26-percent limited partnership interest in her gross estate.
Read the full summary
The decedent, Mrs. Clara K. Hoover, through a revocable trust, held a 26-percent interest in a limited partnership that owned and operated a large ranch. The fair market value of the real estate component of the assets of the limited partnership was eligible, in accordance with sec. 2032A(g), I.R.C., to be replaced by a lower "value" for purposes of inclusion of Mrs. Hoover's 26-percent limited partnership interest in her gross estate. The estate made an appropriate election to take advantage of sec. 2032A, I.R.C. Apart from the use of sec. 2032A, I.R.C., the estate was entitled to a…
1Opinion of the Court
OPINION
Raum, Judge:
Petitioner is the Estate of Clara K. Hoover (Mrs. Hoover), who died on March 7, 1988. The Commissioner determined a gift tax deficiency of $13,960 for the tax year ended December 31, 1987, which has been conceded in full by the Commissioner on brief, and an estate tax deficiency of $994,498, together with a section 66601 addition to estate tax in the amount of $52,391.2 The decedent had a 26-percent interest in a limited partnership that was engaged in the operation of a cattle ranch. After concessions by the parties, the only issue remaining for decision is whether…
2Cases cited4 opinions
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
- Occidental Petroleum Corp. v. CommissionerUnited States Tax Court · 1984
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
- Estate of Maddox v. CommissionerUnited States Tax Court · 1989
3Cited by14 opinions
- Shaw v. Commissioner (In re Estate of Neumann)United States Tax Court · 1996
- Estate of Clara K. Hoover, Deceased Yetta Hoover Bidegain, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
- 15 W. 17th St. LLC v. Comm'rUnited States Tax Court · 2016
- Van Alen v. Comm'rUnited States Tax Court · 2013
- Estate of Clara K. Hoover, Deceased Yetta Hoover Bidegain, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
9 more not listed; retrieve them via the Exa API.