Legal Opinion

Estate of Sommers v. Comm'r

United States Tax Court

Decided August 22, 2017No. Docket No. 9306-07Published

D made valid gifts to Ns, his nieces, in December 2001 and January 2002. See Estate of Sommers v. Commissioner, T.C. Memo. 2013-8. D died in November 2002. W, D's surviving spouse, succeeded to property she owned jointly with D, and D's will bequeathed and devised to W all of his estate remaining after payment of debts and expenses.

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D made valid gifts to Ns, his nieces, in December 2001 and January 2002. See Estate of Sommers v. Commissioner, T.C. Memo. 2013-8. D died in November 2002. W, D's surviving spouse, succeeded to property she owned jointly with D, and D's will bequeathed and devised to W all of his estate remaining after payment of debts and expenses. W succeeded to or was entitled to receive all of the property included in D's gross estate, within the meaning of I.R.C. sec. 2031(a). In accordance with the agreements governing their gifts from D, Ns paid the gift tax due on those gifts. P has filed three…

1Opinion of the Court

ESTATE OF SHELDON C. SOMMERS, DECEASED, STEPHAN C. CHAIT, TEMPORARY ADMINISTRATOR, Petitioner, AND WENDY SOMMERS, JULIE SOMMERS NEUMAN, AND MARY LEE SOMMERS-GOSZ, Intervenors v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Sommers v. Comm'r

Docket No. 9306-07

United States Tax Court

2017 U.S. Tax Ct. LEXIS 41; 149 T.C. No. 8;

August 22, 2017, Filed

Estate of Sommers v. Comm'r, T.C. Memo 2013-8, 2013 Tax Ct. Memo LEXIS 10 (T.C., Jan. 10, 2013)

An appropriate order will be issued.

D made valid gifts to Ns, his nieces, in December 2001 and January 2002. See Estate of Sommers v. Commissioner,…

2Cases cited27 opinions

  1. Bull v. United StatesSupreme Court of the United States · 1935
  2. Riggs v. Del DragoSupreme Court of the United States · 1942
  3. Estate of Sachs v. CommissionerUnited States Tax Court · 1987
  4. Turner v. ColeSupreme Court of New Jersey · 1935
  5. Adele H. Dodd and William A. Dodd, Executors of the Estate of John A. Dodd, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1965

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