Legal Opinion

Wilson v. Comm'r

United States Tax Court

Decided June 21, 1971No. Docket Nos. 3408-69, 3409-69PublishedCited by 16 opinions

1. Decedent's grandson did not owe interest on a land purchase contract at the time of decedent's death; consequently, no claim for such interest is includable in her taxable estate under sec. 2033, I.R.C. 1954. 2. Decedent did not make completed gifts to her children of certificates of deposit or of funds deposited in certain savings accounts, all of which were maintained in the joint names of decedent and one of the children; therefore, such certificates and funds are…

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1. Decedent's grandson did not owe interest on a land purchase contract at the time of decedent's death; consequently, no claim for such interest is includable in her taxable estate under sec. 2033, I.R.C. 1954. 2. Decedent did not make completed gifts to her children of certificates of deposit or of funds deposited in certain savings accounts, all of which were maintained in the joint names of decedent and one of the children; therefore, such certificates and funds are includable in her taxable estate under sec. 2040, I.R.C. 1954. 3. Decedent's deposit of funds in a joint savings account…

1Opinion of the Court

FeatheestoN, Judge:

Respondent determined that each petitioner is liable as transferee for a deficiency of $9,949.74 in the Federal estate tax of the Estate of Stella M. Wilson. The questions presented for decision are:(1) Whether on the date of Stella M. Wilson’s death she was the owner of a contract right entitling her to collect $234.25 in accrued interest from her grandson;(2) Whether Stella M. Wilson made completed gifts to her two adult children of certificates of deposit and of funds deposited in certain savings accounts, all of which were maintained in the joint names of her and one of…

2Cases cited10 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Shurrum v. WattsIdaho Supreme Court · 1958
  3. Chase v. ReidIdaho Supreme Court · 1960
  4. Forest G. Smith, Jr., and Rose Mary Smith v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  5. In Re Chase's EstateIdaho Supreme Court · 1960

5 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Estate of Young v. CommissionerUnited States Tax Court · 1998
  2. Estate of Zaiger v. CommissionerUnited States Tax Court · 1975
  3. Estate of Green v. CommissionerUnited States Tax Court · 1975
  4. First Wisconsin Trust Co. v. United StatesDistrict Court, E.D. Wisconsin · 1982
  5. Florence A. Haneke v. United States of America, Florence A. Haneke v. United StatesCourt of Appeals for the Fourth Circuit · 1977

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