Legal Opinion

Estate of Friedman v. Comm'r

United States Tax Court

Decided July 3, 1963No. Docket Nos. 95074, 95075Published

The decedent, within 3 years of her death, transferred certain properties to her stepchildren in compromise of a dispute between them concerning title to those properties. Although the claim which the stepchildren had was an unliquidated one, release from such a claim has a recognizable value in money or money's worth.

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The decedent, within 3 years of her death, transferred certain properties to her stepchildren in compromise of a dispute between them concerning title to those properties. Although the claim which the stepchildren had was an unliquidated one, release from such a claim has a recognizable value in money or money's worth. Commissioner v. Mesta, 123 F. 2d 986 (C.A. 3, 1941). It appearing that the transaction was otherwise at arm's length, held, the transfer of the properties was made for a full and adequate consideration in money or money's worth. Catherine S. Beveridge, 10 T.C. 915 (1948),…

1Opinion of the Court

Estate of Gertrude Friedman, Deceased, Samuel Friedman, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Friedman v. Comm'r

Docket Nos. 95074, 95075

United States Tax Court

40 T.C. 714; 1963 U.S. Tax Ct. LEXIS 86;

July 3, 1963, Filed

Decision will be entered in Docket No. 95074 under Rule 50.

Decision will be entered in Docket No. 95075 for the petitioner.

The decedent, within 3 years of her death, transferred certain properties to her stepchildren in compromise of a dispute between them concerning title to those properties. Although the claim which the stepchildren had…

2Cases cited11 opinions

  1. Merrill v. FahsSupreme Court of the United States · 1945
  2. Harris v. CommissionerSupreme Court of the United States · 1950
  3. Bailey v. SmithSupreme Court of Florida · 1925
  4. Commissioner of Internal Revenue v. MestaCourt of Appeals for the Third Circuit · 1941
  5. Goetchius v. CommissionerUnited States Tax Court · 1951

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