Estate of Pfohl v. Commissioner
United States Tax Court
U.S. Treasury bonds, otherwise qualified for use at par in payment of Federal estate taxes, were purchased for decedent at a time when she was in a comatose state. The purchase was made pursuant to a power of attorney granted by decedent when she was not in such state. The tender of the bonds in payment of estate taxes by decedent's executor was refused by the Bureau of Public Debt.
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U.S. Treasury bonds, otherwise qualified for use at par in payment of Federal estate taxes, were purchased for decedent at a time when she was in a comatose state. The purchase was made pursuant to a power of attorney granted by decedent when she was not in such state. The tender of the bonds in payment of estate taxes by decedent's executor was refused by the Bureau of Public Debt. Held, since the bonds were eligible for redemption at par in payment of Federal estate taxes under sec. 6312, I.R.C. 1954, they are includable in the gross estate at their par value.
1Opinion of the Court
Estate of Pauline M. Pfohl, Deceased, Louis H. Pfohl, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Pfohl v. Commissioner
Docket No. 10823-76
United States Tax Court
70 T.C. 630; 1978 U.S. Tax Ct. LEXIS 81;
August 7, 1978, Filed
Decision will be entered under Rule 155.
U.S. Treasury bonds, otherwise qualified for use at par in payment of Federal estate taxes, were purchased for decedent at a time when she was in a comatose state. The purchase was made pursuant to a power of attorney granted by decedent when she was not in such state. The tender of the bonds in…
2Cases cited28 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- United States v. Little Lake Misere Land Co.Supreme Court of the United States · 1973
- Bank of America National Trust & Savings Ass'n v. ParnellSupreme Court of the United States · 1956
- Finch v. GoldsteinNew York Court of Appeals · 1927
- Ortelere v. Teachers' Retirement BoardNew York Court of Appeals · 1969
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