Legal Opinion

Du Puy v. Commissioner

United States Tax Court

Decided August 29, 1947No. Docket Nos. 4883, 6874, 6875, 10184Published

1. Valuation -- Closely Held Stock. -- The fair market value of closely held stock determined. 2. Estate Tax -- State Law -- Corporate Distributions Accumulated in Trust -- Section 811 (a). -- Liquidating distributions of a wasting asset corporation accumulated in trust of which decedent was life beneficiary held not includible in the gross estate of the decedent under the provisions of section 811 (a) because the decedent was not entitled thereto under Pennsylvania law. 3.…

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1. Valuation -- Closely Held Stock. -- The fair market value of closely held stock determined. 2. Estate Tax -- State Law -- Corporate Distributions Accumulated in Trust -- Section 811 (a). -- Liquidating distributions of a wasting asset corporation accumulated in trust of which decedent was life beneficiary held not includible in the gross estate of the decedent under the provisions of section 811 (a) because the decedent was not entitled thereto under Pennsylvania law. 3. Estate Tax -- Contemplation of Death -- Section 811 (c). -- Inter vivos transfers to grandchildren in 1935 and 1938 held…

1Opinion of the Court

Estate of Amy H. DuPuy, Deceased, Peoples First National Bank & Trust Company and Eleanor D. Merrick, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent. Eleanor D. Merrick, Petitioner, v. Commissioner of Internal Revenue, Respondent. Charles M. DuPuy, Petitioner, v. Commissioner of Internal Revenue, Respondent

Du Puy v. Commissioner

Docket Nos. 4883, 6874, 6875, 10184

United States Tax Court

9 T.C. 276; 1947 U.S. Tax Ct. LEXIS 117;

August 29, 1947, Promulgated

Decisions will be entered under Rule 50.

1. Valuation -- Closely Held Stock. -- The fair market value of closely held…

2Cases cited14 opinions

  1. McKeown's EstateSupreme Court of Pennsylvania · 1919
  2. Mallory's EstateSupreme Court of Pennsylvania · 1925
  3. Knox's Estate (No. 1)Supreme Court of Pennsylvania · 1937
  4. Hosack v. CrillSuperior Court of Pennsylvania · 1901
  5. Nirdlinger's Estate (No. 1)Supreme Court of Pennsylvania · 1937

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