Legal Opinion
Estate of Rose D'ambrosio, Deceased, Vita D'Ambrosio v. Commissioner of Internal Revenue Service
Court of Appeals for the Third Circuit
Decided November 26, 1996No. 95-7643PublishedCited by 17 opinions
1Opinion of the Court
OPINION OF THE COURT
NYGAARD, Circuit Judge.
Vita D’Ambrosio, executrix of the estate of Rose D’Ambrosio, appeals from a judgment *311of the United States Tax Court upholding a statutory notice of deficiency filed against the estate by the Commissioner of Internal Revenue. The tax court held that, even though the decedent had sold her remainder interest in closely held stock for its fair market value, 26 U.S.C. § 2036(a)(1) brought its entire fee simple value back into her gross estate. We will reverse and remand with the direction that the tax court enter judgment in favor of appellant.
I
The facts…
2Cases cited15 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Merrill v. FahsSupreme Court of the United States · 1945
- Karen Dahn v. United States of America Maureen Ames and Keith FinleyCourt of Appeals for the Tenth Circuit · 1996
10 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Estate of Cyril I. Magnin, Deceased Donald Isaac Magnin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Estate of Theodore Thompson, Deceased, Betsy T. Turner v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2004
- John Michael Wheeler, Independent of the Estate of Elmore K. Melton, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Estate of Abraham v. CommissionerCourt of Appeals for the First Circuit · 2005
- Steinberg v. CommissionerUnited States Tax Court · 2013
12 more not listed; retrieve them via the Exa API.