Estate of Thompson v. Commissioner
United States Tax Court
The decedent (D) owned four farm properties, portions of which P elected to value pursuant to sec. 2032A, I.R.C. 1954. D's will devised an income interest in the farm properties to Brittingham until her death or remarriage. Brittingham is not a "qualified heir" within the meaning of the statute. Brittingham executed a disclaimer of her income interest in the farm properties, for which she was paid $ 18,000 by D's two daughters.
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The decedent (D) owned four farm properties, portions of which P elected to value pursuant to sec. 2032A, I.R.C. 1954. D's will devised an income interest in the farm properties to Brittingham until her death or remarriage. Brittingham is not a "qualified heir" within the meaning of the statute. Brittingham executed a disclaimer of her income interest in the farm properties, for which she was paid $ 18,000 by D's two daughters. Held, Brittingham's income interest in the farm properties is an interest in the property for which special use valuation is sought. Held, further, Brittingham…
1Opinion of the Court
Estate of James U. Thompson, Deceased, Susan T. Taylor, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Thompson v. Commissioner
Docket No. 9879-86
United States Tax Court
89 T.C. 619; 1987 U.S. Tax Ct. LEXIS 133; 89 T.C. No. 43;
September 17, 1987; Reversed January 3, 1989 September 17, 1987, Filed
Decision will be entered pursuant to Rule 155.
The decedent (D) owned four farm properties, portions of which P elected to value pursuant to sec. 2032A, I.R.C. 1954. D's will devised an income interest in the farm properties to Brittingham until her death or…
2Cases cited14 opinions
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
- Estate of David Smith, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
- Estate of Jephson v. CommissionerUnited States Tax Court · 1983
- Estate of William A. Frieders, Deceased, Elmer Frieders v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1982
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