Plessen v. Commissioner
United States Tax Court
In 1931, decedent's father transferred shares of stock to himself and decedent as joint tenants with the right of survivorship. He died in 1947, and she thereupon became the sole owner of the stock. Under the laws of the State wherein the father resided at the time of his death, decedent became liable for that part of his estate taxes attributable to the stock. Decedent died in 1949, and her executor subsequently paid her share of her father's estate tax.
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In 1931, decedent's father transferred shares of stock to himself and decedent as joint tenants with the right of survivorship. He died in 1947, and she thereupon became the sole owner of the stock. Under the laws of the State wherein the father resided at the time of his death, decedent became liable for that part of his estate taxes attributable to the stock. Decedent died in 1949, and her executor subsequently paid her share of her father's estate tax. Held, the deduction for previously taxed property provided by section 812 (c) of the 1939 Code, to which decedent's estate is entitled for…
1Opinion of the Court
Estate of Eleanor G. Plessen, Deceased, the Bank of New York, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Plessen v. Commissioner
Docket No. 51158
United States Tax Court
25 T.C. 1301; 1956 U.S. Tax Ct. LEXIS 231;
March 26, 1956, Filed
Decision will be entered under Rule 50.
In 1931, decedent's father transferred shares of stock to himself and decedent as joint tenants with the right of survivorship. He died in 1947, and she thereupon became the sole owner of the stock. Under the laws of the State wherein the father resided at the time of his death, decedent became liable…
2Cases cited4 opinions
- Central Hanover B. & T. Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1947
- Bahr v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Ackley v. CommissionerUnited States Tax Court · 1955
- Plessen v. CommissionerUnited States Tax Court · 1956