Trammell v. Commissioner
United States Tax Court
For several years prior to his death, decedent was an equal partner with his wife in a business in Nashville, Tennessee, known as "Grace's" which was a ladies ready-to-wear shop handling high class merchandise. "Grace's" enjoyed a very profitable trade and had an excellent reputation in the community for reliability and fair dealings.
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For several years prior to his death, decedent was an equal partner with his wife in a business in Nashville, Tennessee, known as "Grace's" which was a ladies ready-to-wear shop handling high class merchandise. "Grace's" enjoyed a very profitable trade and had an excellent reputation in the community for reliability and fair dealings. In the estate tax return which was filed, decedent's one-half interest in this business was returned at $ 33,966.82, which was the book value of one-half of the assets of the business at the time of decedent's death and included nothing for the value of good…
1Opinion of the Court
OPINION.
Black, Judge:
Originally there were three issues in this proceeding. At the hearing it was agreed that petitioner would be entitled to an additional deduction for attorney’s fees incurred in the present appeal to the Tax Court and that this additional deduction will be settled in a recomputation under Bule 50. Therefore assignment of error (c) is no longer in the case.
Also respondent agrees that petitioner is entitled to an additional deduction for debts existing at the time of decedent’s death, said debts consisting of income tax deficiencies determined against decedent for periods…
2Cases cited2 opinions
- Hoffman v. CommissionerUnited States Tax Court · 1943
- Giannini v. CommissionerCourt of Appeals for the Ninth Circuit · 1945
3Cited by13 opinions
- Solitron Devices, Inc. v. CommissionerUnited States Tax Court · 1983
- Weil v. CommissionerUnited States Tax Court · 1954
- Gannon v. CommissionerUnited States Tax Court · 1954
- Fiorito v. CommissionerUnited States Tax Court · 1959
- Critchfield v. CommissionerUnited States Tax Court · 1959
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