Chastain v. Commissioner
United States Tax Court
At the time of his death (1964) D owned two mortgage notes upon the collection of which he would have realized long-term capital gains of $ 632,402.84 and $ 150,506.49, respectively. Among the bequests made in D's will were: (1) A $ 1 million bequest to D's son, T, which was to include the two mortgage notes, and (2) a residuary gift to a charitable foundation, out of which the estate tax was to be paid.
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At the time of his death (1964) D owned two mortgage notes upon the collection of which he would have realized long-term capital gains of $ 632,402.84 and $ 150,506.49, respectively. Among the bequests made in D's will were: (1) A $ 1 million bequest to D's son, T, which was to include the two mortgage notes, and (2) a residuary gift to a charitable foundation, out of which the estate tax was to be paid. In 1966 T received payment on one of the notes, and reported a $ 632,402.84 long-term capital gain in his income tax return for that year in respect of a decedent, pursuant to sec. 691(a) of…
1Opinion of the Court
Thomas M. Chastain, Petitioner v. Commissioner of Internal Revenue, Respondent
Chastain v. Commissioner
Docket No. 7278-70
United States Tax Court
59 T.C. 461; 1972 U.S. Tax Ct. LEXIS 4; 59 T.C. No. 45;
December 27, 1972, Filed
Decision will be entered under Rule 50.
At the time of his death (1964) D owned two mortgage notes upon the collection of which he would have realized long-term capital gains of $ 632,402.84 and $ 150,506.49, respectively. Among the bequests made in D's will were: (1) A $ 1 million bequest to D's son, T, which was to include the two mortgage notes, and (2) a residuary gift to…
2Cases cited8 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Davidson v. CommissionerSupreme Court of the United States · 1938
- Isabel Collier Read, as of the Estate of Miles Collier, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 1963
- Edna Rice Meissner, Dorothy M. Freeman, and Edwin B. Meissner, Jr., Executors of the Estate of Edwin B. Meissner, Deceased v. The United StatesUnited States Court of Claims · 1966
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