Estate of Arnaud v. Commissioner
United States Tax Court
Petitioner, the estate of a nonresident alien, claimed, under the estate tax convention between the United States and France, a marital deduction and the credit against estate tax allowed by sec. 2010(b), I.R.C. 1954. Held, petitioner is limited to the lower credit allowed by sec. 2102(c). Estate of Burghardt v. Commissioner, 80 T.C. 705 (1983), affd. without published opinion 734 F.2d 3 (3d Cir. 1984), distinguished.
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Petitioner, the estate of a nonresident alien, claimed, under the estate tax convention between the United States and France, a marital deduction and the credit against estate tax allowed by sec. 2010(b), I.R.C. 1954. Held, petitioner is limited to the lower credit allowed by sec. 2102(c). Estate of Burghardt v. Commissioner, 80 T.C. 705 (1983), affd. without published opinion 734 F.2d 3 (3d Cir. 1984), distinguished. Held, further, petitioner's estate tax liability is the lower of that computed under the treaty or under secs. 2101-2108.
1Opinion of the Court
Estate of Jean Simon Andre Arnaud, Deceased, Emile Furlan, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Arnaud v. Commissioner
Docket No. 39812-85
United States Tax Court
90 T.C. 649; 1988 U.S. Tax Ct. LEXIS 38; 90 T.C. No. 39;
April 7, 1988; As amended April 7, 1988 April 7, 1988, Filed
Decision will be entered under Rule 155.
Petitioner, the estate of a nonresident alien, claimed, under the estate tax convention between the United States and France, a marital deduction and the credit against estate tax allowed by sec. 2010(b), I.R.C. 1954. Held, petitioner is…
2Cases cited11 opinions
- Maximov v. United StatesSupreme Court of the United States · 1963
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Andre Maximov, as Trustee for the Benefit of H. Robbin Fedden U/a Dated 10/24/47 v. United StatesCourt of Appeals for the Second Circuit · 1962
- Amelia J. Taylor v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Taylor v. CommissionerUnited States Tax Court · 1956
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