Hagenlocher v. Commissioner
United States Tax Court
Held, on the facts, judgments were includable in decedent's gross estate because they were not assigned or satisfied prior to his death. Held, further, this Court is not bound by an orphans' court decision which reached no determination on the merits as to decedent's interest in the judgments.
1Opinion of the Court
Dawson, Judge:
Despondent determined a deficiency in the Federal estate tax of petitioner in the amount of $10,609.25. All other adjustments having been conceded by the petitioner, the sole issue remaining for decision is whether two judgments of record held by Frank Hagen-locher should be included in his gross estate.
FINDINGS OF FACT
The stipulated facts are hereby found accordingly.
Frank Hagenlocher (hereinafter sometimes referred to as decedent) died intestate on March 1, 1957. Decedent was a resident of Erie, Erie County, Pa.
Decedent’s heirs were his two brothers, William and Ernest, and…
2Cases cited15 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
- United States v. LefflerSupreme Court of the United States · 1837
- Helvering v. BullardSupreme Court of the United States · 1938
10 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Porter v. CommissionerUnited States Tax Court · 1967
- Hagenlocher v. CommissionerUnited States Tax Court · 1964
- Porter v. CommissionerUnited States Tax Court · 1967