Legal Opinion

Estate of Fletcher v. Commissioner

United States Tax Court

Decided January 31, 1990No. Docket No. 37289-87Published

D died 3 hours after H due to a common accident. At the time of H's death, he owned a certificate of deposit in his name followed by the designation "payable on death" to D. D and H also owned U. S. savings bonds on which both names appeared connected by "or." H's gross estate included the certificate and bonds.

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D died 3 hours after H due to a common accident. At the time of H's death, he owned a certificate of deposit in his name followed by the designation "payable on death" to D. D and H also owned U. S. savings bonds on which both names appeared connected by "or." H's gross estate included the certificate and bonds. The Probate Court approved a final accounting reflecting that D was entitled to one-third of the certificate and bonds and that the two surviving children were entitled to one-third each. R determined that the full value of the certificate and bonds was includable in D's gross estate.…

1Opinion of the Court

Estate of Margaret A. Fletcher, Deceased, Mary M. Starr, Administratrix, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Fletcher v. Commissioner

Docket No. 37289-87

United States Tax Court

94 T.C. 49; 1990 U.S. Tax Ct. LEXIS 5; 94 T.C. No. 5;

January 31, 1990January 31, 1990, Filed

Decision will be entered under Rule 155.

D died 3 hours after H due to a common accident. At the time of H's death, he owned a certificate of deposit in his name followed by the designation "payable on death" to D. D and H also owned U. S. savings bonds on which both names appeared connected by "or."…

2Cases cited15 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Helvering v. StuartSupreme Court of the United States · 1942
  3. Free v. BlandSupreme Court of the United States · 1962
  4. Cook v. BevillSupreme Court of Arkansas · 1969
  5. United States v. ChandlerSupreme Court of the United States · 1973

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