GREEN v. COMMISSIONER
United States Tax Court
1. Upon settlement of their father's estate in 1931, the petitioners, as distributees, each received one-half of the residuary estate.
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1. Upon settlement of their father's estate in 1931, the petitioners, as distributees, each received one-half of the residuary estate. Several years later the respondent determined a deficiency in estate tax against the said estate, which with the interest thereon was paid in equal amounts by the petitioners in 1939. Petitioner Ralph J. Green similarly paid in 1939 a deficiency with interest thereon in the estate tax of his deceased wife, he having received in a prior year, as beneficiary of her estate, one-fourth of the assets. Held, that such parts of the interest on the said estate tax…
1Opinion of the Court
OPINION.
Smith, Judge:
These proceedings, which were consolidated for hearing, are for the redetermination of deficiencies in income tax for the year 1939 of $1,201.94 in the case of Ralph J. Green, and $728.18 in the case of Lawrence E. Green. In the petition filed by the former it is alleged that the respondent erred in disallowing the deduction from gross income of (1) $4,143 interest paid in satisfaction of his obligation, as a transferee, to pay a deficiency in estate tax on the estate of his deceased father, which had been distributed to him and his brother Lawrence in equal shares in…
2Cases cited1 opinion
- Brown v. CommissionerUnited States Tax Court · 1942
3Cited by16 opinions
- California and Hawaiian Sugar Refining Corporation, Limited v. The United StatesUnited States Court of Claims · 1962
- Pearson v. CommissionerUnited States Tax Court · 1944
- Commissioner of Internal Revenue v. Henderson's EstateCourt of Appeals for the Fifth Circuit · 1945
- Timken v. CommissionerUnited States Tax Court · 1946
- Smith v. CommissionerUnited States Tax Court · 1946
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