Ashforth v. Commissioner
United States Board of Tax Appeals
More than two years prior to death, and not in contemplation of death, decedent executed and delivered to her husband, without monetary consideration, a mortgage for $700,000 on certain real estate situated in the State of Connecticut.
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More than two years prior to death, and not in contemplation of death, decedent executed and delivered to her husband, without monetary consideration, a mortgage for $700,000 on certain real estate situated in the State of Connecticut. Held, the interest of decedent in the property, under the law of Connecticut, which is required to be included in the value of her gross estate by section 302(a) of the Revenue Act of 1926, is the full value of the land at the date of decedent's death. Held, further, that, the mortgage not having been contracted for an adequate and full consideration in money…
1Opinion of the Court
OPINION.
Ahundell :
This is a proceeding for the redetermination of a deficiency m estate tax in the amount of $113,201.18. Seven assignments of error were set forth in the petition and amendments thereto, upon which issue was joined, but all of these issues have been settled by the parties, except one. The issues so settled will be given effect in the redetermination of the deficiency under Rule 50, in accordance with the agreement of the parties filed at the hearing.
The parties also stipulated certain facts, in addition to which petitioners offered the testimony of two witnesses and certain…
2Cases cited16 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Corliss v. BowersSupreme Court of the United States · 1930
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Tyler v. United StatesSupreme Court of the United States · 1930
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3Cited by6 opinions
- Tiffany v. CommissionerUnited States Tax Court · 1967
- Estate of Davis v. CommissionerUnited States Tax Court · 1972
- Ashforth v. CommissionerUnited States Board of Tax Appeals · 1934
- Estate of Davis v. CommissionerUnited States Tax Court · 1972
- Gray v. CommissionerUnited States Board of Tax Appeals · 1941
1 more not listed; retrieve them via the Exa API.