Estate of Gamble v. Commissioner
United States Tax Court
The decedent made gifts in contemplation of his death and paid Federal and California gift taxes with respect to those gifts prior to his death. The date of death value of the gifts was includable in the value of the decedent's Federal gross estate and in the State inheritance tax base. A credit against State inheritance taxes was allowed for the State gift taxes paid by the decedent.
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The decedent made gifts in contemplation of his death and paid Federal and California gift taxes with respect to those gifts prior to his death. The date of death value of the gifts was includable in the value of the decedent's Federal gross estate and in the State inheritance tax base. A credit against State inheritance taxes was allowed for the State gift taxes paid by the decedent. Held, the decedent had no interest in property at the time of his death such that under sec. 2033, I.R.C. 1954, the value of his Federal gross estate includes the amount he paid as State gift taxes prior to his…
1Opinion of the Court
Estate of George E. P. Gamble, Crocker National Bank, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Gamble v. Commissioner
Docket No. 8352-74
United States Tax Court
69 T.C. 942; 1978 U.S. Tax Ct. LEXIS 157;
March 16, 1978, Filed
Decision will be entered for the petitioner.
The decedent made gifts in contemplation of his death and paid Federal and California gift taxes with respect to those gifts prior to his death. The date of death value of the gifts was includable in the value of the decedent's Federal gross estate and in the State inheritance tax base. A credit…
2Cases cited28 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Knowlton v. MooreSupreme Court of the United States · 1900
- New York Trust Co. v. EisnerSupreme Court of the United States · 1921
- Ingram v. United StatesSupreme Court of the United States · 1959
- United States v. MichelSupreme Court of the United States · 1931
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