Legal Opinion
Higgs' Estate v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided September 28, 1950No. 10154PublishedCited by 30 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
This controversy, one of first impression, concerns the taxability, as part of the decedent’s gross estate, of the value of a survivorship annuity payable to the- decedent’s '• widow. The annuity in favor of the widow resulted from the exercise, by the decedent during his lifetime, of an option extended to him in a group retirement benefit contract arranged by his employer with a commercial insurance company, the full consideration for which, in this instance, was paid by the employer.
The Tax Court, four judges dissenting, held the value of the survivorship annuity…
2Cases cited12 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Estate of Spiegel v. CommissionerSupreme Court of the United States · 1949
- Brown v. RoutzahnCourt of Appeals for the Sixth Circuit · 1933
7 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Estate of Daniel McNichol Deceased, Ellen McNichol Evangelista and Joseph G. McNichol Executors v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Fusz v. CommissionerUnited States Tax Court · 1966
- Carrie Kramer and Julius Kramer, Executors of the Estate of Abraham Kramer, Deceased v. The United StatesUnited States Court of Claims · 1969
- Commissioner of Internal Revenue v. Twogood's EstateCourt of Appeals for the Second Circuit · 1952
- Estate of Fried v. CommissionerUnited States Tax Court · 1970
25 more not listed; retrieve them via the Exa API.