Legal Opinion

Peters v. Commissioner

United States Tax Court

Decided June 22, 1966No. Docket No. 4203-64PublishedCited by 7 opinions

Decedent inherited real property from her husband which had a value at that time of approximately $ 33,000. A number of years later when the property had a value of approximately $ 64,000, she created by gift a joint tenancy of this property with her son. Thereafter and prior to decedent's death, the son expended from his own funds approximately $ 16,000 in improvements and additions to the property.

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Decedent inherited real property from her husband which had a value at that time of approximately $ 33,000. A number of years later when the property had a value of approximately $ 64,000, she created by gift a joint tenancy of this property with her son. Thereafter and prior to decedent's death, the son expended from his own funds approximately $ 16,000 in improvements and additions to the property. At the time of decedent's death the property had a value of $ 95,000. Held, under the facts of this case, the amount to be included in decedent's gross estate on account of this property is the…

1Opinion of the Court

Respondent determined a deficiency in the Federal estate tax of petitioner in the amount of $17,798.69. Tlie sole issue for our decision is the extent to which a certain piece of improved realty, which was jointly owned by the decedent and her son as of the date of her death, is includable in her gross estate.

FINDINGS OF FACT

All of the facts have been stipulated, and the stipulation of facts, together with the exhibit attached thereto, is incorporated herein and made a part of our findings by reference.

Edna V. T. Peters (hereinafter sometimes referred to as decedent) died testate on February…

2Cited by7 opinions

  1. Estate of Young v. CommissionerUnited States Tax Court · 1998
  2. Estate of Edna v. T. Peters, Deceased, T. Graham Peters v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1967
  3. Estate of Silvester v. CommissionerUnited States Tax Court · 1977
  4. Estate of Balazs v. CommissionerUnited States Tax Court · 1981
  5. Estate of Wayne-Chi Young, Tsai-Hsiu Hsu Yang v. CommissionerUnited States Tax Court · 1998

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