Estate of Iversen v. Commissioner
United States Tax Court
Decedent and his former wife while domiciled in Pennsylvania in 1950 entered into a separation agreement which was binding whether or not a divorce was later obtained by either.
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Decedent and his former wife while domiciled in Pennsylvania in 1950 entered into a separation agreement which was binding whether or not a divorce was later obtained by either. The agreement provided for monthly payments to the wife for her life or until her remarriage, these payments to be secured by a trust created by decedent the income of which was payable to decedent so long as he was not in default with the monthly payments and the corpus of which was to be distributed to decedent upon the death or remarriage of his former wife. After the execution of the agreement and the creation of…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency of $225,446.01 in the Federal estate tax of the Estate of Robert F. Iversen. The issues for decision are (1) whether any consideration in money or money’s worth was received by decedent for the creation of a trust to secure payments to his former wife so that the value of the trust assets includable in the gross estate should be reduced by the value of such consideration under section 2043(a), I.R.C. 1954,1 or (2) whether the value of the obligation of the decedent’s estate under a separation agreement incident to a divorce is a claim…
2Cases cited36 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Harris v. CommissionerSupreme Court of the United States · 1950
- Estate of Christ v. Comm'rUnited States Tax Court · 1970
- Estate of Daisy F. Christ, Deceased, Robert Johnson Christ v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
31 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Estate of Fenton v. CommissionerUnited States Tax Court · 1978
- Estate of Joseph P. Kosow, Deceased. Eleanor C. Kosow, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1995
- Estate of Satz v. CommissionerUnited States Tax Court · 1982
- Estate of Robert F. Iversen, Deceased. Pittsburgh National Bank, Agent for John D. Iversen v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977
- Estate of Fenton v. CommissionerUnited States Tax Court · 1978
2 more not listed; retrieve them via the Exa API.