Legal Opinion
Commissioner of Internal Revenue v. Kann's Estate
Court of Appeals for the Third Circuit
Decided April 19, 1949No. 9694PublishedCited by 15 opinions
1Opinion of the Court
BIGGS, Chief Judge.
*358■ Mrs. Bertha -F. Kann, the decedent, sold certain securities to-her children in'return for their unsecured promises to pay her life annuities. The question presented for our determination is: Did the Tax Court err in holding’1 that the decedent realized no taxable gain under. Section 111(a) of the Internal Revenue Code, 26 U.S.'C.A. § 111(a), and the applicable regulation on the ground that annuity contracts undertaken by individual obligors do not have an ascertainable fair market value as a matter of law? The pertinent statute and regulation are in the margin.2 See also…
2Cases cited10 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Lloyd v. CommissionerUnited States Board of Tax Appeals · 1936
- Evans v. RothensiesCourt of Appeals for the Third Circuit · 1940
- Cassatt v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Raymond v. CommissionerUnited States Board of Tax Appeals · 1939
5 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- Lazarus v. CommissionerUnited States Tax Court · 1972
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Fehrs Finance Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Eighth Circuit · 1973
- Estate of Bell v. CommissionerUnited States Tax Court · 1973
10 more not listed; retrieve them via the Exa API.