Estate of Heckscher v. Commissioner
United States Tax Court
Held, value of shares of stock of a closely held investment company which represented a small minority interest in the company, determined.
Read the full summary
Held, value of shares of stock of a closely held investment company which represented a small minority interest in the company, determined. Held, further, attorney's fees paid directly by a beneficiary of a trust, the value of which was includable in decedent's gross estate by virtue of his exercise by will of a general power of appointment with respect thereto, for services rendered in an action brought by the trustee for instructions as to distribution of the trust estate, are not deductible by the estate of decedent as administration expenses under sec. 2053(b), I.R.C. 1954.
1Opinion of the Court
Drennen, Judge:
Respondent determined a deficiency in the amount of $49,152.41 in petitioner’s estate tax and an addition to tax in the amount of $12,288.10 under section 6651(a), I.R.C. 1954. Following certain concessions by the parties, the issues remaining for decision are: (1) The value at the date of decedent’s death of 2,500 shares of stock of Anahma Realty Corp. which were properly included in decedent’s gross estate; and (2) whether attorney’s fees incurred by decedent’s wife in defending her claim to trust property appointed to her under decedent’s will are deductible by the estate as…
2Cases cited12 opinions
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Messing v. CommissionerUnited States Tax Court · 1967
- Mosells Silvey Pitner v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Burrow Trust v. CommissionerUnited States Tax Court · 1963
- Toeller v. CommissionerUnited States Tax Court · 1946
7 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Stanley Works v. CommissionerUnited States Tax Court · 1986
- Harwood v. CommissionerUnited States Tax Court · 1984
- Snyder v. CommissionerUnited States Tax Court · 1989
- Estate of Jephson v. CommissionerUnited States Tax Court · 1983
39 more not listed; retrieve them via the Exa API.