Legal Opinion

Drazen v. Commissioner

United States Tax Court

Decided April 6, 1967No. Docket No. 5505-64Published

Decedent died testate in 1960 at the age of 49. Respondent included in decedent's gross estate under sec. 2040 (Joint Interests), I.R.C. 1954, a total amount of $ 32,262.34, representing the total of four joint bank accounts of decedent and his wife, payable to either or the survivor.

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Decedent died testate in 1960 at the age of 49. Respondent included in decedent's gross estate under sec. 2040 (Joint Interests), I.R.C. 1954, a total amount of $ 32,262.34, representing the total of four joint bank accounts of decedent and his wife, payable to either or the survivor. Held, except for one deposit of $ 1,031.05 made by decedent's wife, it has not been shown that any part of the total amount was contributed from the wife's funds, other than those funds she acquired from the decedent for less than an adequate and full consideration in money or money's worth.

1Opinion of the Court

Estate of Robert T. Drazen, Deceased, Vera H. Drazen, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent

Drazen v. Commissioner

Docket No. 5505-64

United States Tax Court

48 T.C. 1; 1967 U.S. Tax Ct. LEXIS 123;

April 6, 1967, Filed

Decision will be entered under Rule 50.

Decedent died testate in 1960 at the age of 49. Respondent included in decedent's gross estate under sec. 2040 (Joint Interests), I.R.C. 1954, a total amount of $ 32,262.34, representing the total of four joint bank accounts of decedent and his wife, payable to either or the survivor. Held, except for one deposit…

2Cases cited4 opinions

  1. Frizzell v. CommissionerUnited States Tax Court · 1947
  2. Howard v. CommissionerUnited States Tax Court · 1947
  3. Harvey v. United StatesCourt of Appeals for the Seventh Circuit · 1950
  4. Drazen v. CommissionerUnited States Tax Court · 1967

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