Caplan v. Commissioner
United States Tax Court
Held, an amount of $ 125,584.90 allegedly owing by petitioner's decedent to her husband's estate at the time of her death is not deductible under section 2053 of the Internal Revenue Code of 1954 since petitioner has failed to establish that such alleged indebtedness was a legally enforceable obligation.
1Opinion of the Court
Estate of Sarah Caplan, Deceased, Yetta C. Levin, Independent Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Caplan v. Commissioner
Docket No. 3634-62
United States Tax Court
42 T.C. 446; 1964 U.S. Tax Ct. LEXIS 97; 21 Oil & Gas Rep. 110;
May 28, 1964, Filed
Decision will be entered under Rule 50.
Held, an amount of $ 125,584.90 allegedly owing by petitioner's decedent to her husband's estate at the time of her death is not deductible under section 2053 of the Internal Revenue Code of 1954 since petitioner has failed to establish that such alleged indebtedness was a legally…
2Cases cited4 opinions
- First-Mechanics Nat. Bank v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1940
- Glascock v. CommissionerCourt of Appeals for the Fourth Circuit · 1939
- Caplan v. CommissionerUnited States Tax Court · 1964
- Estate of Clement v. CommissionerUnited States Tax Court · 1949