Manscill v. Commissioner
United States Tax Court
Decedent died testate. On decedent's estate tax return, the executor allocated amounts between Fund A and Fund B, and elected to treat Fund B as qualified terminable interest property (QTIP) for the surviving spouse. The parties agreed that Fund A qualifies for the marital deduction. In Manscill I, this Court held that Fund B did not qualify for QTIP treatment.
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Decedent died testate. On decedent's estate tax return, the executor allocated amounts between Fund A and Fund B, and elected to treat Fund B as qualified terminable interest property (QTIP) for the surviving spouse. The parties agreed that Fund A qualifies for the marital deduction. In Manscill I, this Court held that Fund B did not qualify for QTIP treatment. Petitioner filed a timely motion for reconsideration, requesting that the Court conclude that the formula clause in decedent's will is not subject to sec. 403(e)(3), Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 172; that…
1Opinion of the Court
ESTATE OF JOHN D. MANSCILL, DECEASED, FRANCES D. MANSCILL WEST, EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Manscill v. Commissioner
Docket No. 32405-86
United States Tax Court
T.C. Memo 1992-571; 1992 Tax Ct. Memo LEXIS 588; 64 T.C.M. (CCH) 905; T.C.M. (RIA) 92571;
September 24, 1992, Filed
Petitioner's motion for reconsideration will be denied; decision will be entered under Rule 155.
Decedent died testate. On decedent's estate tax return, the executor allocated amounts between Fund A and Fund B, and elected to treat Fund B as qualified terminable interest property (QTIP)…
2Cases cited17 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Humes v. United StatesSupreme Court of the United States · 1928
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Gerald Leuhsler, Beverly Leuhsler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Haft Trust v. CommissionerUnited States Tax Court · 1974
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