Northern Trust Co. v. Commissioner
United States Board of Tax Appeals
1. The value of securities purchased by decedent with proceeds from sale of securities acquired from a prior decedent who died within five years and on whose estate the tax was paid, was acquired in exchange within the meaning of section 403(a)(2) of the Revenue Act of 1921 and should be deducted from the value of the decedent's gross estate. 2. Where the property previously taxed within five years is commingled with all of the other funds of the decedent, and funeral and…
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1. The value of securities purchased by decedent with proceeds from sale of securities acquired from a prior decedent who died within five years and on whose estate the tax was paid, was acquired in exchange within the meaning of section 403(a)(2) of the Revenue Act of 1921 and should be deducted from the value of the decedent's gross estate. 2. Where the property previously taxed within five years is commingled with all of the other funds of the decedent, and funeral and administration expenses and debts of the decedent are paid out of such commingled funds, and such "other funds" are at all…
1Opinion of the Court
APPEAL OF NORTHERN TRUST CO., EXECUTOR, ESTATE OF LUCY C. UNDERWOOD.
Northern Trust Co. v. Commissioner
Docket No. 2473.
United States Board of Tax Appeals
9 B.T.A. 1310; 1928 BTA LEXIS 4263;
January 14, 1928, Promulgated
1. The value of securities purchased by decedent with proceeds from sale of securities acquired from a prior decedent who died within five years and on whose estate the tax was paid, was acquired in exchange within the meaning of section 403(a)(2) of the Revenue Act of 1921 and should be deducted from the value of the decedent's gross estate.
2. Where the property previously taxed…
2Cases cited7 opinions
- Rodenbough v. CommissionerUnited States Board of Tax Appeals · 1925
- Appeal of Estate of HoffmanUnited States Board of Tax Appeals · 1926
- Archbold v. CommissionerUnited States Board of Tax Appeals · 1927
- Appeal of Northern Trust Co.United States Board of Tax Appeals · 1928
- Pelton v. CommissionerUnited States Board of Tax Appeals · 1927
2 more not listed; retrieve them via the Exa API.