Legal Opinion

Matthews v. Commissioner

United States Tax Court

Decided March 28, 1944No. Docket No. 112390Published

1. Decedent and a business associate, who were both officers and stockholders of X corporation, entered into a reciprocal agreement under which the survivor was to have the option to purchase for a limited time after the death of the other and for a stipulated price all of the shares of X corporation which the other should own at the time of his death. Both parties were free to dispose of any or all of such shares during their lifetime.

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1. Decedent and a business associate, who were both officers and stockholders of X corporation, entered into a reciprocal agreement under which the survivor was to have the option to purchase for a limited time after the death of the other and for a stipulated price all of the shares of X corporation which the other should own at the time of his death. Both parties were free to dispose of any or all of such shares during their lifetime. Held, that the shares of X stock which decedent owned at the time of his death should be included in his gross estate at their fair market value at the time…

1Opinion of the Court

Estate of James H. Matthews, Fidelity Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Matthews v. Commissioner

Docket No. 112390

United States Tax Court

3 T.C. 525; 1944 U.S. Tax Ct. LEXIS 160;

March 28, 1944, Promulgated

Decision will be entered under Rule 50.

1. Decedent and a business associate, who were both officers and stockholders of X corporation, entered into a reciprocal agreement under which the survivor was to have the option to purchase for a limited time after the death of the other and for a stipulated price all of the shares of X corporation which…

2Cases cited34 opinions

  1. Helvering v. HallockSupreme Court of the United States · 1940
  2. Hassett v. WelchSupreme Court of the United States · 1938
  3. May v. HeinerSupreme Court of the United States · 1930
  4. Klein v. United StatesSupreme Court of the United States · 1931
  5. Edwards v. SlocumSupreme Court of the United States · 1924

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