Legal Opinion

Hamar v. Commissioner

United States Tax Court

Decided August 11, 1964No. Docket Nos. 2088-62, 3726-62, 3727-62Published

1. Held, that petitioner Jeanne Hamar, as successor trustee of the testamentary trust created under the will of a decedent, is severally liable as a transferee of said decedent's estate in the limited amount determined by the Commissioner, for the unpaid deficiency in estate tax and addition to tax owed by said decedent's estate, plus interest according to law; and that the existence of such liability is not prevented by the facts: (1) That the residuary legatee of the…

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1. Held, that petitioner Jeanne Hamar, as successor trustee of the testamentary trust created under the will of a decedent, is severally liable as a transferee of said decedent's estate in the limited amount determined by the Commissioner, for the unpaid deficiency in estate tax and addition to tax owed by said decedent's estate, plus interest according to law; and that the existence of such liability is not prevented by the facts: (1) That the residuary legatee of the decedent's estate also is severally liable as a transferee for said taxes and interest; or (2) that the estate tax…

1Opinion of the Court

Jeanne Hamar, Successor Trustee Under the Will of Lottie Hamar, Deceased, Transferee, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Hamar v. Commissioner

Docket Nos. 2088-62, 3726-62, 3727-62

United States Tax Court

42 T.C. 867; 1964 U.S. Tax Ct. LEXIS 62;

August 11, 1964, Filed

In docket Nos. 2088-62 and 3726-62, decisions will be entered for the respondent.

In docket No. 3727-62, decision will be entered for the petitioner.

1. Held, that petitioner Jeanne Hamar, as successor trustee of the testamentary trust created under the will of a decedent, is severally liable as a…

2Cases cited23 opinions

  1. Helvering v. MitchellSupreme Court of the United States · 1938
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. Bruning v. United StatesSupreme Court of the United States · 1964
  5. City of New York v. SaperSupreme Court of the United States · 1949

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