Estate of Branson v. Commissioner
United States Tax Court
P reported the date-of-death fair market values of the stock of S and W as $ 181.50 and $ 485, respectively, per share. P sold some of the S stock for $ 335 per share and all the W stock for $ 850 per share. The gain realized on the sales by P was distributed to the residuary legatee, M, who reported the gain on her Federal income tax return and paid the income tax due. R determined a deficiency in P's estate tax liability.
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P reported the date-of-death fair market values of the stock of S and W as $ 181.50 and $ 485, respectively, per share. P sold some of the S stock for $ 335 per share and all the W stock for $ 850 per share. The gain realized on the sales by P was distributed to the residuary legatee, M, who reported the gain on her Federal income tax return and paid the income tax due. R determined a deficiency in P's estate tax liability. R's determination was based on his assertion that at the date of death the fair market values of the S and W shares were $ 300 and $ 850, respectively, per share. In…
1Opinion of the Court
ESTATE OF FRANK A. BRANSON, DECEASED, MARY M. MARCH, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Branson v. Commissioner
No. 10028-95
United States Tax Court
113 T.C. 6; 1999 U.S. Tax Ct. LEXIS 28; 113 T.C. No. 2;
July 13, 1999, Filed
Decision will be entered under Rule 155.
P reported the date-of-death fair market values of the
stock of S and W as $ 181.50 and $ 485, respectively, per share. P
sold some of the S stock for $ 335 per share and all the W stock
for $ 850 per share. The gain realized on the sales by P was
distributed to the residuary legatee, M, who…
Also in this document: Concurrence; Dissent.
2Cases cited61 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Helvering v. TaylorSupreme Court of the United States · 1935
- Bull v. United StatesSupreme Court of the United States · 1935
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
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