Hart v. Commissioner
United States Tax Court
Decedent was obligated to pay a life annuity to a woman who was 79 years of age at the date of decedent's death. For the purpose of a deduction from gross estate respondent valued the annuitant's claim against decedent's estate in accordance with the method and table set forth in Regulations 80 (1937 Ed.), article 10 (i), which is the same as Regulations 105, section 81.10 (i). Held, petitioner has failed to prove that the method used or the result reached by respondent is…
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Decedent was obligated to pay a life annuity to a woman who was 79 years of age at the date of decedent's death. For the purpose of a deduction from gross estate respondent valued the annuitant's claim against decedent's estate in accordance with the method and table set forth in Regulations 80 (1937 Ed.), article 10 (i), which is the same as Regulations 105, section 81.10 (i). Held, petitioner has failed to prove that the method used or the result reached by respondent is erroneous, and his determination is accordingly sustained.
1Opinion of the Court
OPINION.
Ajrundell, Judge:
The question to be decided is whether respondent erred in his determination that $13,645.03 is the amount deductible from gross estate with respect to the claim of Irene N. Collord for an annuity of $3,500 during her lifetime. The petition alleges that respondent erred in determining such value, and further that:
* * * The true value of this debt should have been determined to be the ascertainable cost to the Estate of acquiring a similar type of (annuity) contract in the open market at the time of the death of the decedent or, in the alternative, the sum of $19,600.00…
2Cases cited2 opinions
- Simpson v. United StatesSupreme Court of the United States · 1920
- In re the Estate of BowkerNew York Surrogate's Court · 1935
3Cited by14 opinions
- Du Pont v. CommissionerUnited States Tax Court · 1943
- Bartman v. CommissionerUnited States Tax Court · 1948
- Dix v. CommissionerUnited States Tax Court · 1966
- Koshland v. CommissionerUnited States Tax Court · 1948
- McMurtry v. CommissionerUnited States Tax Court · 1951
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