Estate of Hoffman v. Commissioner
United States Tax Court
All the assets of H and W consisted of community property in which W had a one-half vested interest under California law. H's will provided for the establishment of a testamentary trust out of the residue of his estate after a minor bequest of his interest in certain tangible personal property to W. His will also provided for the payment of all death taxes out of the residue of his estate.
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All the assets of H and W consisted of community property in which W had a one-half vested interest under California law. H's will provided for the establishment of a testamentary trust out of the residue of his estate after a minor bequest of his interest in certain tangible personal property to W. His will also provided for the payment of all death taxes out of the residue of his estate. Upon his death, all of the community property was subject to administration as part of his probate estate prior to distribution of W's one-half interest therein. The probate estate in fact paid all the…
1Opinion of the Court
Estate of Gertrude Hoffman, Deceased, Arnold Hoffman and Sharlene Leventhal, Coexecutors, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Hoffman v. Commissioner
Docket No. 3326-80
United States Tax Court
78 T.C. 1069; 1982 U.S. Tax Ct. LEXIS 78; 78 T.C. No. 76;
June 17, 1982, Filed
Decision will be entered under Rule 155.
All the assets of H and W consisted of community property in which W had a one-half vested interest under California law. H's will provided for the establishment of a testamentary trust out of the residue of his estate after a minor bequest of his interest in…
2Cases cited8 opinions
- Gregory v. CommissionerUnited States Tax Court · 1963
- Commissioner of Internal Revenue v. Mildred Irene SiegelCourt of Appeals for the Ninth Circuit · 1957
- Estate of De LaveagaCalifornia Supreme Court · 1958
- Bishop v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
- Bishop v. CommissionerUnited States Tax Court · 1945
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