Pelton v. Commissioner
United States Board of Tax Appeals
The value of property purchased by decedent through investments of proceeds of sale of securities acquired by decedent as a share in the estate of a prior decedent who died within five years and on whose estate an estate tax was paid, was acquired in exchange within the meaning of section 403(a)(2) of the Revenue Act of 1921 and such value is not properly to be included in the value of decedent's gross estate.
1Opinion of the Court
*1146OPINION.
Murdock :
The respondent defends his action in regard to these items by the argument that under section 403 (a) (2) of the Revenue Act of 1921, the right to the deduction is lost, where there has been more than one exchange and that in the .present case there has been more than one exchange. Both parties concede that the question here is exactly the same as the question previously decided by this Board in the Appeal of Elmer E. Rodenbough, Executor, 1 B. T. A. 477. In the Roderibough case we had an equivalent set of facts and we were there concerned with a similar provision of the…
2Cited by2 opinions
- Archbold v. CommissionerUnited States Board of Tax Appeals · 1927
- Northern Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1928