Legal Opinion
Estate of Lydia G. Maxwell, Deceased First National Bank of Long Island Victor C. McCuaig Jr., Executors v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided August 23, 1993No. 1233, Docket 92-4230PublishedCited by 38 opinions
1Opinion of the Court
LASKER, Senior District Judge:
This appeal presents challenges to the tax court’s interpretation of section 2036(a) of the Internal Revenue Code, relating to “Transfers with retained life estate.” The petitioner, the Estate of Lydia G. Maxwell, contends that the tax court erred in holding that the transaction at issue (a) was a transfer with retained life estate within the meaning of 26 U.S.C. § 2036 and (b) was not a bona fide sale for adequate and full consideration under that statute.
The decision of the tax court is affirmed.
I
On March 14, 1984, Lydia G. Maxwell (the “decedent”) conveyed her…
2Cases cited19 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- United States v. ByrumSupreme Court of the United States · 1972
- 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
- Jane C. Guynn, of the Estate of Vena E. Calvert, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1971
- Estate of Maria M. Coxe Skinner, Deceased, Neil McFee Skinner and Girard Trust Corn Exchange Bank, Executors v. United StatesCourt of Appeals for the Third Circuit · 1963
14 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Kimbell v. United StatesCourt of Appeals for the Fifth Circuit · 2004
- Estate of Theodore Thompson, Deceased, Betsy T. Turner v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2004
- John Michael Wheeler, Independent of the Estate of Elmore K. Melton, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Estate of Abraham v. CommissionerCourt of Appeals for the First Circuit · 2005
- Albert Strangi, Deceased, Rosalie Gulig, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2005
33 more not listed; retrieve them via the Exa API.