Estate of Johnson v. Commissioner
United States Tax Court
Decedent, an employee of a State university, died in possession of two annuity contracts. Held, under sec. 2039(c)(3), I.R.C. 1954, petitioner may exclude from the gross estate that portion of the annunity proceeds attributable to contributions made by decedent's employer.
1Opinion of the Court
Fat, Judge:
Respondent determined deficiencies in petitioner’s estate tax of $4,449.39. Concessions having been made, the only issue to be decided is to what extent the value of two annuity contracts owned by decedent must be included in his gross estate.
FINDINGS OF FACT
Some of the facts have been stipulated and are, together with the exhibits attached to the stipulation of facts, incorporated herein by this reference.
The decedent, Leslie E. Johnson (hereafter referred to as Leslie or decedent), died in Story County, Iowa, on December 20, 1967. Ruth Johnson, decedent’s wife, was duly appointed…
2Cases cited1 opinion
- Slayton v. CommissionerUnited States Board of Tax Appeals · 1926
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- Estate of Johnson v. CommissionerUnited States Tax Court · 1971
- Estate of Perl v. CommissionerUnited States Tax Court · 1981
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