Legal Opinion

Estate of Holding v. Commissioner

United States Tax Court

Decided July 31, 1958No. Docket No. 65341Published

Decedent, Maggie M. Holding, in 1952 and for several years prior thereto, owned some valuable unimproved land near the city of Raleigh, North Carolina. She sold it that year at what she considered an advantageous price. She gave part of the proceeds of the sale to her children, grandchildren, and a daughter-in-law who had remarried subsequent to her husband's death.

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Decedent, Maggie M. Holding, in 1952 and for several years prior thereto, owned some valuable unimproved land near the city of Raleigh, North Carolina. She sold it that year at what she considered an advantageous price. She gave part of the proceeds of the sale to her children, grandchildren, and a daughter-in-law who had remarried subsequent to her husband's death. Although the donor was 87 years of age she was in good health at the time the gifts were made and the dominant motive of the donor in making the gifts was the satisfaction of seeing her children, grandchildren, and daughter-in-law…

1Opinion of the Court

Estate of Maggie M. Holding, Deceased, Willis A. Holding, Sr., and Mildred Holding Stockard, Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Holding v. Commissioner

Docket No. 65341

United States Tax Court

30 T.C. 988; 1958 U.S. Tax Ct. LEXIS 115;

July 31, 1958, Filed

Decision will be entered under Rule 50.

Decedent, Maggie M. Holding, in 1952 and for several years prior thereto, owned some valuable unimproved land near the city of Raleigh, North Carolina. She sold it that year at what she considered an advantageous price. She gave part of the proceeds of the sale to…

2Cases cited4 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Levi v. United StatesUnited States Court of Claims · 1936
  3. Bradley v. SmithCourt of Appeals for the Seventh Circuit · 1940
  4. Estate of Holding v. CommissionerUnited States Tax Court · 1958

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