Estate of Goldstone v. Commissioner
United States Tax Court
Decedent died in an airplane accident with her husband and three children. There was no sufficient evidence that the deaths were other than simultaneous. Under applicable State law, decedent was presumed to survive her husband.
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Decedent died in an airplane accident with her husband and three children. There was no sufficient evidence that the deaths were other than simultaneous. Under applicable State law, decedent was presumed to survive her husband. Decedent's husband created an insurance trust that was divided at his death into two separate funds -- trust "A" and trust "B." Decedent owned two insurance policies on her husband's life; one-half of each policy was payable to trust A and one-half of each policy was payable to trust B. Only the transfer to trust B is in issue herein. Held, decedent made a gift of the…
1Opinion of the Court
OPINION
Wilbur, Judge:
Respondent determined a deficiency in petitioner’s Federal gift tax for the calendar quarter ended March 31, 1974, in the amount of $9,599.72. Respondent further determined a deficiency in petitioner’s Federal estate tax in the amount of $48,087.52. By way of amended answer, respondent claimed an increase of $8,493.46 in the proposed Federal estate tax deficiency, making the overall estate tax deficiency $56,580.98.
The following issues are presented here for our decision.(1) Whether Lillian Goldstone, who was killed with her husband in an airplane accident, made a taxable…
2Cases cited12 opinions
- Goodman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Estate of Gloria A. Lion, Deceased, Morton E. Rome and George L. Clarke, Executors v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1971
- Goodman v. CommissionerUnited States Tax Court · 1944
- Estate of Ellen M. Wien, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Old Kent Bank and Trust Company v. United StatesDistrict Court, W.D. Michigan · 1968
7 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Marks v. CommissionerUnited States Tax Court · 1990
- Estate of Grossinger v. CommissionerUnited States Tax Court · 1982
- Estate of Goldstone v. CommissionerUnited States Tax Court · 1982
- Estate of Marks v. CommissionerUnited States Tax Court · 1990