Estate of Fawcett v. Commissioner
United States Tax Court
Decedent owned 17,538.2 acres of ranch land in Texas. In 1964 decedent borrowed $ 235,000 from the Travelers Insurance Co. This indebtedness was evidenced by a promissory note and secured by a deed of trust on the ranch property which were cosigned by decedent and his wife.
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Decedent owned 17,538.2 acres of ranch land in Texas. In 1964 decedent borrowed $ 235,000 from the Travelers Insurance Co. This indebtedness was evidenced by a promissory note and secured by a deed of trust on the ranch property which were cosigned by decedent and his wife. In 1965 the decedent conveyed a life interest in one-half of the ranch in equal proportions to his four children with remainder in trust for their issue, leaving the decedent with an undivided one-half interest in the property. The fair market value of decedent's interest in the property was included in his gross estate,…
1Opinion of the Court
Sterrett, Judge:
The respondent determined a deficiency in the Federal estate tax due from the Estate of Horace K. Fawcett in the amount of léO^GO.SS.1 The issues before the Court are: (1) Whether the petitioner is entitled to reduce the value of the gross estate of Horace K. Fawcett by the full amount of a note due to the Travelers Insurance Co. secured by 17,538.2 acres of ranch land in Texas though the total gross estate included only the value of Horace K. Fawcett’s undivided one-half interest in this land; (2) the value at the time of his death of decedent’s undivided one-half interest in…
2Cases cited4 opinions
- Estate of Courtney v. CommissionerUnited States Tax Court · 1974
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1934
- Seagrist v. CommissionerUnited States Board of Tax Appeals · 1940
- Scott v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by31 opinions
- Wolfsen Land & Cattle Co. v. CommissionerUnited States Tax Court · 1979
- Estate of Young v. CommissionerUnited States Tax Court · 1998
- Knight v. CommissionerUnited States Tax Court · 2000
- Estate of Johnson v. CommissionerUnited States Tax Court · 1981
- Estate of Egger v. CommissionerUnited States Tax Court · 1989
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