Neuhoff v. Commissioner
United States Tax Court
Petitioner and her husband purchased U.S. Treasury bonds (flower bonds) which were redeemable at their par value to the extent they were utilized to pay Federal estate tax. At the time the bonds were acquired, petitioner obtained a vested interest in one-half of the bonds under the community property law of Texas.
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Petitioner and her husband purchased U.S. Treasury bonds (flower bonds) which were redeemable at their par value to the extent they were utilized to pay Federal estate tax. At the time the bonds were acquired, petitioner obtained a vested interest in one-half of the bonds under the community property law of Texas. Following acquisition of the bonds, petitioner's husband died and one-half of the bonds were distributed to petitioner as her share of the community interest, while the remaining half was included in her husband's gross estate as his share of the community interest. To the extent…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable years 1971 and 1972 in the respective amounts of $18,899.75 and $5,267.69.
The issues for our decision are:(1) Whether the Consent Fixing Period of Limitation Upon Assessment of Income Tax (Form 872) signed by petitioner operated, under section 6501(c)(4), I.R.C. 1954,1 to prevent the period of limitations for the taxable years in issue from expiring prior to the issuance of the statutory notice of deficiency; and(2) Whether petitioner’s basis in her community one-half interest in certain…
2Cases cited11 opinions
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Arnold v. LeonardTexas Supreme Court · 1925
- Hopkins v. BaconSupreme Court of the United States · 1930
- Bankers Trust Company, as of the Will of Harriet Delta Ellis, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1960
- Houghton v. CommissionerUnited States Tax Court · 1967
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3Cited by23 opinions
- Stark v. CommissionerUnited States Tax Court · 1986
- Mecom v. CommissionerUnited States Tax Court · 1993
- Estate of Cristofani v. CommissionerUnited States Tax Court · 1991
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1997
- Rome I, Ltd. v. CommissionerUnited States Tax Court · 1991
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