Legal Opinion
Purnell v. United States
District Court, W.D. Pennsylvania
Decided September 23, 1971No. Civ. 69-246PublishedCited by 4 opinions
1Opinion of the Court
OPINION and ORDER
KNOX, District Judge.
This suit for refund of federal estate taxes involves one of the more abstruse and obscure branches of the Pennsylvania law of decedent’s estates. The rule formerly was that where under a will, personal property was awarded directly to a life tenant for life with remainder over, the life tenant was treated as a debtor to the remainder man in the amount of the personal property received by the life tenant. The relationship between life tenant and remainder man was that of debtor and creditor, not trustee and beneficiary. Fortunately, the number of cases…
2Cases cited17 opinions
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Bemis Bro. Bag Co. v. United StatesSupreme Court of the United States · 1933
- Appeal of ReiffSupreme Court of Pennsylvania · 1889
- First-Mechanics Nat. Bank v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1940
- Powell's EstateSupreme Court of Pennsylvania · 1940
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3Cited by4 opinions
- Cyclops Corp. v. United StatesDistrict Court, W.D. Pennsylvania · 1976
- Spaeder v. United StatesDistrict Court, W.D. Pennsylvania · 1978
- Estate of Schlotterer v. United StatesDistrict Court, W.D. Pennsylvania · 1976
- Mok Partners v. United StatesDistrict Court, N.D. Illinois · 1987