Estate of Frost v. Commissioner
United States Tax Court
W, D's spouse and executor of D's estate, filed gift tax returns showing that no tax was due upon D's transfer of 60 percent of the stock in his wholly owned corporation to two of his children in 1982 and the transfer of the remainder of the stock to them in 1983. W filed an estate tax return for D's estate reporting no taxable gifts. W also elected to take her statutory share of D's estate. She thereby claimed a one-third interest in certain real estate.
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W, D's spouse and executor of D's estate, filed gift tax returns showing that no tax was due upon D's transfer of 60 percent of the stock in his wholly owned corporation to two of his children in 1982 and the transfer of the remainder of the stock to them in 1983. W filed an estate tax return for D's estate reporting no taxable gifts. W also elected to take her statutory share of D's estate. She thereby claimed a one-third interest in certain real estate. Pursuant to a subsequent agreement, she ceded that real estate to D's sons. 1. Held: R has failed to prove by clear and convincing evidence…
1Opinion of the Court
ESTATE OF RICHARD M. FROST, DECEASED, DIANA L. FROST, EXECUTOR; DIANA L. FROST; CYNTHIA L. BUTLER; RICHARD M. FROST, JR.; LAURIE A. JACOBS TRUST, DIANA L. FROST, TRUSTEE; AND RICHARD M. FROST TRUST, DIANA L. FROST AND RICHARD M. FROST, JR., TRUSTEES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Frost v. Commissioner
Docket No. 17333-89
United States Tax Court
T.C. Memo 1993-94; 1993 Tax Ct. Memo LEXIS 89; 65 T.C.M. (CCH) 2101;
March 18, 1993, Filed
W, D's spouse and executor of D's estate, filed gift tax returns showing that no tax was due upon D's transfer of 60 percent of…
2Cases cited33 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Beaver v. CommissionerUnited States Tax Court · 1970
- Otsuki v. CommissionerUnited States Tax Court · 1969
- Commissioner v. SternSupreme Court of the United States · 1958
28 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- In Re Estate of Denman, Texas Court of Appeals, 4th District (San Antonio)2008
- Armstrong v. CommissionerUnited States Tax Court · 2000
- O'Sullivan v. CommissionerUnited States Tax Court · 1994
- Armstrong v. CommissionerUnited States Tax Court · 2000
- Estate of Gilbert M. Denman, Jr., Texas Court of Appeals, 4th District (San Antonio)2008
2 more not listed; retrieve them via the Exa API.