Wells v. Commissioner
United States Tax Court
Held, shares in open-end investment companies or mutual funds were properly valued for estate tax purposes at the public offering price on the date of death in accordance with sec. 20.2031-8(b), Estate Tax Regs., rather than at the redemption price.
1Opinion of the Court
OPINION
Tietjens, Judge:
The Commissioner determined a deficiency in estate tax in the amount of $2,328.25.
The only issue is whether the Commissioner properly valued for estate tax purposes the shares of certain open-end investment companies. He valued them pursuant to section 20.2031-8 (b) ,1 Estate Tax Regs., the validity of which is in contention.
All of the facts are stipulated and so far as pertinent are as follows: The petitioner is Estate of Frances Foster Wells, deceased, Eugene P. Ruehlmann, executor. Eugene P. Ruehlmann’s business address at the time this petition was filed was and now…
2Cases cited7 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. RyersonSupreme Court of the United States · 1941
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Mearkle's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1942
- Gould v. CommissionerUnited States Tax Court · 1950
2 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Eugene P. Ruehlmann, of the Estate of Frances Foster Wells, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- Bertha O. Howell v. United StatesCourt of Appeals for the Seventh Circuit · 1969
- Davis v. United StatesDistrict Court, C.D. California · 1969
10 more not listed; retrieve them via the Exa API.