Estate of Robinson v. Commissioner
United States Tax Court
Held, the value of an installment obligation includable in decedent's gross estate may not be discounted for estimated income taxes payable by the estate (or the beneficiaries) on the gain included in installments collectible after decedent's death.
1Opinion of the Court
Featherston, Judge:
Respondent determined an estate tax deficiency in the amount of $153,493.46 for the estate of decendent, G. R. Robinson. The parties have disposed of certain issues, and the only one remaining for decision is whether, for estate tax valuation purposes under section 2031,1 an installment promissory note in the principal amount of $1,120,000 at the date of decedent’s death should be discounted in order to reflect possible Federal income taxes that may apply in respect of subsequent installment collections.
FINDINGS OF FACT
Decedent G. R. Robinson died testate on February 27,…
2Cases cited4 opinions
- Harrison v. CommissionerUnited States Tax Court · 1952
- Hedrick v. CommissionerUnited States Tax Court · 1974
- Bessie Stanley, Estate of Joseph Stanley, Deceased, Bessie Stanley, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Stanley v. CommissionerUnited States Tax Court · 1963
3Cited by20 opinions
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- John David Smith, of the Estate of Louis R. Smith, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 2004
- Estate of Piper v. CommissionerUnited States Tax Court · 1979
- Estate of Kahn v. Comm'rUnited States Tax Court · 2005
- Bergquist v. Comm'rUnited States Tax Court · 2008
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