Estate of Stubblefield v. Commissioner
United States Tax Court
In 1955 decedent and his wife conveyed two farms, one each, to their son and daughter. For the next 18 years, however, decedent used the farms for his crops and livestock without formal reservation or agreement. Although the children held legal title to the land and exercised some rights in the land, they did not interfere with decedent's use of the property. During the last 5 of the 18 years decedent paid rent to his children for the use of the farms.
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In 1955 decedent and his wife conveyed two farms, one each, to their son and daughter. For the next 18 years, however, decedent used the farms for his crops and livestock without formal reservation or agreement. Although the children held legal title to the land and exercised some rights in the land, they did not interfere with decedent's use of the property. During the last 5 of the 18 years decedent paid rent to his children for the use of the farms. Decedent surrendered completely any and all interest in the farms no later than May 1973, the same month in which he conveyed to his children…
1Opinion of the Court
ESTATE OF J. BRITTON STUBBLEFIELD, DECEASED, RICHARD B. STUBBLEFIELD and RUBY HARPER, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Stubblefield v. Commissioner
Docket No. 3397-77.
United States Tax Court
T.C. Memo 1981-353; 1981 Tax Ct. Memo LEXIS 397; 42 T.C.M. (CCH) 342; T.C.M. (RIA) 81353;
July 6, 1981
In 1955 decedent and his wife conveyed two farms, one each, to their son and daughter. For the next 18 years, however, decedent used the farms for his crops and livestock without formal reservation or agreement. Although the children held legal title to the…
2Cases cited25 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Tauber v. CommissionerUnited States Tax Court · 1955
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