Buckwalter v. Commissioner
United States Tax Court
1. Unamortized portion of amount owed by decedent's son to decedent in a certain loan transaction held to be an interest in property owned by decedent at the time of his death and therefore includable in his gross estate. Sec. 2033, I.R.C. 1954. 2. Certain remainder bequests to charity held not deductible because the possibility that such gifts might not in fact be paid over to the charities was not so remote as to be negligible.
1Opinion of the Court
The Commissioner determined a deficiency in estate tax in the amount of $25,984.70. Of the various adjustments resulting in that deficiency only three are contested by petitioner, namely, the inclusion of $7,150.94 in the gross estate in respect of a certain transaction between the decedent and one of his sons, and the disallowance of two claimed charitable deductions in the amounts of $5,000 and $43,900.56, respectively.
FINDINGS OF FACT
Most of the facts have been stipulated, and, as stipulated, are incorporated herein by reference.
Abraham Lincoln Buckwalter, hereinafter referred to as…
2Cases cited9 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Newton Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
- United States v. Bertha DeanCourt of Appeals for the First Circuit · 1955
4 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Varian v. CommissionerUnited States Tax Court · 1966
- Estate of Rowan v. CommissionerUnited States Tax Court · 1970
- Woodworth v. CommissionerUnited States Tax Court · 1966
- Estate of Moss v. CommissionerUnited States Tax Court · 1980
- Estate of Gooel v. CommissionerUnited States Tax Court · 1977
17 more not listed; retrieve them via the Exa API.