Legal Opinion

Hodge v. Commissioner

United States Tax Court

Decided September 8, 1943No. Docket No. 102134Published

A died intestate leaving an estate of over $ 500,000. He had three heirs, one of whom was his son, B. Before A's death B had borrowed $ 80,000 from A and had given him notes in this amount and collateral security. Prior to A's death B was insolvent.

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A died intestate leaving an estate of over $ 500,000. He had three heirs, one of whom was his son, B. Before A's death B had borrowed $ 80,000 from A and had given him notes in this amount and collateral security. Prior to A's death B was insolvent. After A's death his administrators and the Commissioner of Internal Revenue agreed to a valuation of B's notes, for estate tax purposes, at a value placed upon the collateral of $ 28,190. In a partial distribution to the heirs made by A's administrators, B was given $ 167,949 which included his own notes at their full face value. At the same time,…

1Opinion of the Court

Estate of Edwin Hodge, Deceased, Mrs. Frances D. Hodge and Thomas D. Hodge, Administrators, Petitioners, v. Commissioner of Internal Revenue, Respondent

Hodge v. Commissioner

Docket No. 102134

United States Tax Court

2 T.C. 643; 1943 U.S. Tax Ct. LEXIS 73;

September 8, 1943, Promulgated

Decision will be entered of no deficiency.

A died intestate leaving an estate of over $ 500,000. He had three heirs, one of whom was his son, B. Before A's death B had borrowed $ 80,000 from A and had given him notes in this amount and collateral security. Prior to A's death B was insolvent. After A's death his…

2Cases cited1 opinion

  1. Hodge v. CommissionerUnited States Tax Court · 1943

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