McRae v. Commissioner
United States Board of Tax Appeals
1. The full value of the community property held by the decedent and his wife is includable in his gross estate for estate tax purposes. 2. By deeds executed and delivered in 1915 the decedent conveyed certain real property to his wife and daughter.
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1. The full value of the community property held by the decedent and his wife is includable in his gross estate for estate tax purposes. 2. By deeds executed and delivered in 1915 the decedent conveyed certain real property to his wife and daughter. Such action, coupled with acceptance by the donees, constituted completed gifts inter vivos of the property conveyed, even though the deeds were not placed on record until 1925. 3. Securities purchased with funds derived from the sale of a parcel of the real estate conveyed to the wife are included in the decedent's gross estate in the absence of…
1Opinion of the Court
opinion.
Seawell:
The respondent has determined a deficiency of $4,844 in estate tax on account of the estate of Philip McRae, who died July 12, 1925, at the age of 84. The issues are whether there should be included as a part of the gross estate of decedent (1) the full value of community property and (2) the value of certain rea] property, notes, and stock as transfers made in contemplation of death or intended to take effect in possession or enjoyment at or after death. The parties are in agreement as to the value of the property in dispute.
No evidence was offered concerning the first issue…
2Cases cited6 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Ruiz v. DowCalifornia Supreme Court · 1896
- McCarthy v. Security Trust & Savings BankCalifornia Supreme Court · 1922
- Williams v. CommissionerUnited States Board of Tax Appeals · 1932
- Melczer v. CommissionerUnited States Board of Tax Appeals · 1931
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Estate of Glass v. CommissionerUnited States Tax Court · 1981
- Estate of Levine v. CommissionerUnited States Tax Court · 1968
- McRae v. CommissionerUnited States Board of Tax Appeals · 1934