Estate of Harrison v. Commissioner
United States Tax Court
H and W boarded their private aircraft in July of 1993 but never arrived at their destination. Subsequently, probate orders were entered presuming identical April 1, 1994, dates of death and finding it more probable than not that the airplane crashed en route. The will of each spouse presumed survival by the other in circumstances where order of death was unknown and transferred a life estate to such surviving spouse.
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H and W boarded their private aircraft in July of 1993 but never arrived at their destination. Subsequently, probate orders were entered presuming identical April 1, 1994, dates of death and finding it more probable than not that the airplane crashed en route. The will of each spouse presumed survival by the other in circumstances where order of death was unknown and transferred a life estate to such surviving spouse. For estate tax purposes, the transferred life estates were valued on the basis of actuarial tables, and each estate took a credit for tax on prior transfers pursuant to sec.…
1Opinion of the Court
ESTATE OF JUDITH U. HARRISON, DECEASED, RICHARD J. TEJEDA, EXECUTOR, AND ESTATE OF KENNETH R. HARRISON, DECEASED, RICHARD J. TEJEDA, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Harrison v. Commissioner
No. 16018-98
United States Tax Court
115 T.C. 161; 2000 U.S. Tax Ct. LEXIS 59; 115 T.C. No. 13;
August 22, 2000, Filed
Decision will be entered under Rule 155.
H and W boarded their private aircraft in July of 1993 but
never arrived at their destination. Subsequently, probate orders
were entered presuming identical April 1, 1994, dates of death
and finding it more…
2Cases cited10 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Industrial Trust Co. v. United StatesSupreme Court of the United States · 1935
- Lederer v. Fidelity Trust Co.Supreme Court of the United States · 1925
- Estate of McLendon v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
- 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
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