Cain v. Comm'r
United States Tax Court
Decedent sold without reservation or contingency stock in a family-owned corporation to the corporation for $ 150,000. The corporation was to pay $ 6,000 at the time the stock was transferred and $ 1,000 per month for 12 years or until decedent's death, whichever occurred first. When decedent died the balance remaining due under the contract was $ 44,135. Held, that no part of the purchase price or the stock should be included in the decedent's gross estate.
1Opinion of the Court
OPINION.
Fat, Judge:
The Commissioner determined a deficiency in estate tax of $2,391.58 in connection with the Estate of Martha Kang Dis-borough, deceased, hereinafter referred to as the estate. This proceeding involves the liability of the petitioner as transferee of the assets of the estate.1 The only issue to be decided is whether the amount of $44,135, representing the balance due decedent at the time of her death under a sales contract with King’s Indiana Billiard Company, Inc., should be included as part of her estate, when under the terms of the sales contract the purchaser’s (King’s…
2Cases cited5 opinions
- Bergan v. CommissionerUnited States Tax Court · 1943
- Hirsh v. United StatesUnited States Court of Claims · 1929
- Welch v. HallCourt of Appeals for the First Circuit · 1943
- Johnson v. CommissionerUnited States Board of Tax Appeals · 1928
- Security Trust & Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1928
3Cited by11 opinions
- Buckwalter v. CommissionerUnited States Tax Court · 1966
- Daniel J. Mahoney Jr., of the Estate of James M. Cox Jr. v. United StatesCourt of Appeals for the Sixth Circuit · 1987
- Estate of Moss v. CommissionerUnited States Tax Court · 1980
- Estate of Cooper v. CommissionerUnited States Tax Court · 1980
- Buckwalter v. CommissionerUnited States Tax Court · 1966
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