Shedd v. Commissioner
United States Tax Court
Held, where at the time of decedent's death there was no enforcible claim against her estate, such claim being contingent upon litigation involving another estate, it is proper to consider events occurring after decedent's death in order to determine the amount which the estate may properly deduct.
1Opinion of the Court
opinion.
Fay, Judge:
The Commissioner determined a deficiency in estate tax of $27,433.15. The issues presented for decision are:(1) Whether petitioner may deduct under section 2053 of the Internal Revenue Code of 1954 the sum of $29,385.35 due and originally paid to the estate of Harrison P. Shedd, in view of the fact that the estate of Mary Redding Shedd, subsequent to the filing of its estate tax return, recovered from the estate of Harrison P. Shedd the sum of $27,015.17.(2) Whether the enactment of section 93 of the 1958 Technical Amendments Act and the allowance in January 1961 of the…
2Cases cited17 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Fuller v. CommissionerUnited States Tax Court · 1953
- Fuller v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Estate of Harrison P. Shedd, Deceased First National Bank of Arizona, Phoenix v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
- Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1929
12 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Labay v. CommissionerUnited States Tax Court · 1970
- Estate of Hagmann v. CommissionerUnited States Tax Court · 1973
- Marshall Naify Revocable Trust v. United StatesCourt of Appeals for the Ninth Circuit · 2012
- Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- Estate of Van Horne v. CommissionerUnited States Tax Court · 1982
31 more not listed; retrieve them via the Exa API.