Legal Opinion

Caplan v. Commissioner

United States Tax Court

Decided May 28, 1964No. Docket No. 3634-62Published

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

  1. First-Mechanics Nat. Bank v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1940
  2. Glascock v. CommissionerCourt of Appeals for the Fourth Circuit · 1939
  3. Caplan v. CommissionerUnited States Tax Court · 1964
  4. Estate of Clement v. CommissionerUnited States Tax Court · 1949

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