Solowey v. Commissioner
United States Tax Court
Pleadings -- Constitutional Question. -- A constitutional question will not be considered in the absence of pleadings properly raising such a question.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $30,263.42 in estate tax. One error assigned was settled by stipulation. The other is that “The respondent erroneously included for Federal estate, tax purposes insurance and transfers in the gross estate as property of decedent at date of death in the amount of $105,622.87.” The case was. submitted upon a stipulation of facts which is adopted as the findings of fact.
Louis Solowey, the decedent, died on August 4, 1946. The estate tax return was filed with the collector of internal revenue for the second district of New York.
The…
2Cases cited1 opinion
- Tyler v. United StatesSupreme Court of the United States · 1930
3Cited by16 opinions
- Yagoda v. CommissionerUnited States Tax Court · 1962
- Edelman v. CommissionerUnited States Tax Court · 1962
- Isenbergh v. CommissionerUnited States Tax Court · 1959
- Carlton v. CommissionerUnited States Tax Court · 1960
- Estate of Freeman v. CommissionerUnited States Tax Court · 1976
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