Legal Opinion
Lavere C. Senft, Administrator of the Estate of Elmer J. Writer v. United States
Court of Appeals for the Third Circuit
Decided June 29, 1963No. 14099_1PublishedCited by 11 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
Is the descent of property to a state under its intestacy laws a transfer of such property within the meaning of Section 2055(a) of the Internal Revenue Code of 1954, 1 which provides, in effect, for the exemption from federal estate taxes “of all bequests, legacies, devises, or transfers * * * “to or for the use of * * * any State * **”?
The District Court answered the question in the negative 2 and this appeal followed. The issue is one of first impression.
The relevant undisputed facts are:
Elmer J. Writer died intestate May 23,1957, in York, Pennsylvania. He was not…
2Cases cited15 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Young Men's Christian Assn. of Columbus v. DavisSupreme Court of the United States · 1924
- Cammarano v. United StatesSupreme Court of the United States · 1959
- United States v. Leslie Salt Co.Supreme Court of the United States · 1956
10 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
- Harlowe E. Bowes and Harris Trust and Savings Bank, Etc. v. United StatesCourt of Appeals for the Seventh Circuit · 1979
- Estate of Pickard v. CommissionerUnited States Tax Court · 1973
- Matter of Estate of NovotnyDistrict Court, S.D. New York · 1978
- In re the Estate of O'BrineNew York Surrogate's Court · 1971
6 more not listed; retrieve them via the Exa API.