Sokolow v. Commissioner
United States Board of Tax Appeals
1. The entire community estate of a husband and wife, residents of California, is properly included in the gross estate of the husband. 2. The respondent is not estopped to reassert a tax liability theretofore abated by him. 3. Assessment and/or collection of the tax here involved is not barred by the statute of limitations.
1Opinion of the Court
*350OPINION.
Lansdon:
This is a proceeding under section 316 of the Revenue Act of 1926. The respondent asserts that these petitioners are liable for the payment of estate taxes alleged to be due on the estate of Max F. Ihmsen, in the amount of $988.42. The petitioners, who are the executors of the transferee and sole beneficiary of the estate of Max F. Ihmsen, allege: (1) That only one-half of the community estate held by husband and wife in California should be included in the gross estate of the deceased husband; (2) that the respondent is without authority to determine any tax liability in…
2Cases cited1 opinion
- United States v. RobbinsSupreme Court of the United States · 1926
3Cited by4 opinions
- Berry v. WestoverDistrict Court, S.D. California · 1947
- Schildhaus v. CommissionerUnited States Tax Court · 1969
- Boysen v. CommissionerUnited States Tax Court · 1954
- Sokolow v. CommissionerUnited States Board of Tax Appeals · 1931