Legal Opinion

Garrison v. Commissioner

United States Board of Tax Appeals

Decided December 26, 1930No. Docket No. 31627Published

1. ESTATE TAXES. - Held that respondent did not err in including in the gross estate of the decedent the value of the real estate situated in Missouri which was held by the decedent and his wife as tenants by the entirety.

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1. ESTATE TAXES. - Held that respondent did not err in including in the gross estate of the decedent the value of the real estate situated in Missouri which was held by the decedent and his wife as tenants by the entirety. Tyler v. United States,281 U.S. 497. 2. Held, further, the fact that real estate in Missouri may not be included in the gross estate of a decedent under the provisions of section 302(a), Act of 1924 (Crooks v. Harrelson,282 U.S. 55) does not operate to prevent property held by the decedent and another as tenants by the entirety from being included in the gross estate where…

1Opinion of the Court

MARY S. GARRISON AND ST. LOUIS UNION TRUST CO., EXECUTORS AND TRUSTEES UNDER THE WILL OF OLIVER L. GARRISON, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Garrison v. Commissioner

Docket No. 31627.

United States Board of Tax Appeals

21 B.T.A. 904; 1930 BTA LEXIS 1769;

December 26, 1930, Promulgated

1. ESTATE TAXES. - Held that respondent did not err in including in the gross estate of the decedent the value of the real estate situated in Missouri which was held by the decedent and his wife as tenants by the entirety. Tyler v. United States,281 U.S. 497.

2. Held, further,…

2Cases cited3 opinions

  1. Crooks v. HarrelsonSupreme Court of the United States · 1930
  2. Tyler v. United StatesSupreme Court of the United States · 1930
  3. Garrison v. CommissionerUnited States Board of Tax Appeals · 1930

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