Estate of Pfohl v. Commissioner
United States Tax Court
U.S. Treasury bonds issued in the name of decedent were of a type eligible for use in payment of Federal estate tax liabilities. The Bureau of Public Debt refused to honor the bonds on the ground that decedent was incompetent at the time they were acquired. Held, that this Court has jurisdiction to determine the extent to which the bonds are includable in decedent's estate and the issue of eligibility incident thereto.
1Opinion of the Court
OPINION
Tannenwald, Judge:
In his notice of deficiency, respondent determined, among other things, that certain U.S. Treasury bonds, of a type eligible for use in payment of estate tax liabilities, were includable in decedent’s gross estate at their par value rather than their fair market value at the date of death. See Bankers Trust Co. v. United States, 284 F.2d 587 (2d Cir. 1960); Rev. Rul. 69-489, 1969-2 C.B. 172; Rev. Proc. 69-18, 1969-2 C.B. 300. The deficiency notice went on to state that the inclusion of such bonds at par valué-
is made solely for protective purposes in the event that…
2Cases cited10 opinions
- Sunshine Anthracite Coal Co. v. AdkinsSupreme Court of the United States · 1940
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Union Leader Corporation v. Newspapers of New England Inc., Haverhill Gazette Company v. Union Leader CorporationCourt of Appeals for the First Circuit · 1960
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- McGowan v. CommissionerUnited States Tax Court · 1976
5 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Estate of Papson v. CommissionerUnited States Tax Court · 1980
- Estate of Pfohl v. CommissionerUnited States Tax Court · 1978
- Jones v. CommissionerUnited States Tax Court · 1982
- Doner v. CommissionerUnited States Tax Court · 1984
- Estate of Papson v. CommissionerUnited States Tax Court · 1980
3 more not listed; retrieve them via the Exa API.