Hoffman v. Connell
California Court of Appeal
1Opinion of the Court
Opinion
JONES, P. J.
The executors of the estate of Constance T. Cummings contend the trial court erred when it ruled they were obligated to pay California estate tax on property which Ms. Cummings did not own. We agree and will reverse the judgment entered by the trial court.
I. Factual and Procedural Background
Constance T. Cummings (Connie) was married to Robert S. Cummings (Robert) who was a resident of St. Thomas, the United States Virgin Islands. It was a second marriage for both of them. Robert had a son named Donald from a prior marriage.
Robert died on November 3, 1988. His will…
2Cases cited12 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- E.H. McDowell in No. 83-3008 v. Michael Paiewonsky, in No. 83-3007Court of Appeals for the Third Circuit · 1985
- Will Flitcroft and Agnes D. Flitcroft v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Reagh v. KelleyCalifornia Court of Appeal · 1970
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3Cited by6 opinions
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- In Re Estate of ClaeyssensCalifornia Court of Appeal · 2008
- Burkey v. StateCalifornia Court of Appeal · 2008
- United States v. WalkerDistrict Court, S.D. California · 2009
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