Haggett v. Commissioner
United States Tax Court
1. Respondent, in determining the deficiency in estate tax, included in decedent's gross estate one-half the commuted value, $ 24,901.72, of a certain annuity contract, as a transfer during decedent's life, and the remaining one-half as property previously taxed. Petitioner contends that, with respect to the annuity contract, the decedent made no taxable transfer.
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1. Respondent, in determining the deficiency in estate tax, included in decedent's gross estate one-half the commuted value, $ 24,901.72, of a certain annuity contract, as a transfer during decedent's life, and the remaining one-half as property previously taxed. Petitioner contends that, with respect to the annuity contract, the decedent made no taxable transfer. Held, respondent erred in including any part of the commuted value of the annuity contract as a taxable transfer by the decedent. No amount with respect to the annuity contract is, therefore, to be treated here as property…
1Opinion of the Court
OPINION.
Leech, Judge-.
This opinion supersedes an unpublished opinion promulgated by this Court on December 30, 1949, which was withdrawn and vacated by order of this Court on February 1,1950, pursuant to a petition filed by counsel for the petitioner on January 27,1950.
This proceeding involves a deficiency in estate tax in the amount of $11,079.26. The issues presented are:(1) Whether the respondent erred in including in the gross estate the commuted value of an annuity contract issued by the Mutual Life Insurance Co. of New York on March 22,1938.(2) Whether the respondent erred in his…
2Cases cited5 opinions
- Brown v. CommissionerUnited States Tax Court · 1949
- Sinclaire v. CommissionerUnited States Tax Court · 1949
- Brown v. MacgillCourt of Appeals of Maryland · 1898
- Scott v. KeaneCourt of Appeals of Maryland · 1898
- Price v. PitzerCourt of Appeals of Maryland · 1876
3Cited by6 opinions
- Wadewitz v. CommissionerUnited States Tax Court · 1963
- Second Nat. Bank of Danville, Ill. v. DallmanCourt of Appeals for the Second Circuit · 1954
- In Re Estate of Ida Jarvis Pyle. Robert M. Pyle v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1963
- The National City Bank of Cleveland, of the Estate of Pearl C. Dauby, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1966
- Haggett v. CommissionerUnited States Tax Court · 1950
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