Haggett v. Commissioner
United States Tax Court
1. Respondent, in determining the deficiency in estate tax, included in decedent's gross estate one-half the commuted value, $ 24,901.72, of a certain annuity contract, as a transfer during decedent's life, and the remaining one-half as property previously taxed. Petitioner contends that, with respect to the annuity contract, the decedent made no taxable transfer.
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1. Respondent, in determining the deficiency in estate tax, included in decedent's gross estate one-half the commuted value, $ 24,901.72, of a certain annuity contract, as a transfer during decedent's life, and the remaining one-half as property previously taxed. Petitioner contends that, with respect to the annuity contract, the decedent made no taxable transfer. Held, respondent erred in including any part of the commuted value of the annuity contract as a taxable transfer by the decedent. No amount with respect to the annuity contract is, therefore, to be treated here as property…
1Opinion of the Court
Estate of Susie C. Haggett, Deceased, Safe Deposit and Trust Company of Baltimore, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Haggett v. Commissioner
Docket No. 16302
United States Tax Court
14 T.C. 325; 1950 U.S. Tax Ct. LEXIS 264;
March 1, 1950, Promulgated
Decision will be entered under Rule 50.
1. Respondent, in determining the deficiency in estate tax, included in decedent's gross estate one-half the commuted value, $ 24,901.72, of a certain annuity contract, as a transfer during decedent's life, and the remaining one-half as property previously taxed. Petitioner…
2Cases cited6 opinions
- Brown v. CommissionerUnited States Tax Court · 1949
- Sinclaire v. CommissionerUnited States Tax Court · 1949
- Brown v. MacgillCourt of Appeals of Maryland · 1898
- Scott v. KeaneCourt of Appeals of Maryland · 1898
- Haggett v. CommissionerUnited States Tax Court · 1950
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