Legal Opinion

Collins v. Auger

Court of Appeals for the Eighth Circuit

Decided May 8, 1978No. 77-1469PublishedCited by 57 opinions

1Opinion of the Court

JAMESON, Senior District Judge.

The executor of the estate of Helen Baker Jenner, deceased, appeals from a decision of the Tax Court holding that the commission the estate paid to the underwriters for the public sale of a large block of stock through a registered secondary offering was not a deductible administrative expense under section 2053(a)(2) of the Internal Revenue Code of 1954.1 36 T.C.M. (CCH) 241 (1977). This court has jurisdiction pursuant to section 7482 of the Code. We reverse.

Factual Background

Helen Baker Jenner, a resident of Illinois, died testate on March 24, 1971. The…

2Cases cited9 opinions

  1. Estate of David Smith, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
  2. Huntington v. CommissionerUnited States Board of Tax Appeals · 1937
  3. T. S. Ballance, Administrator De Bonis Non With the Will Annexed of the Estate of Samuel D. Jarvis, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1965
  4. Estate of Mary F. Colton Park, Detroit Bank and Trust Company, Administrator With Will Annexed v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973
  5. In Re Estate of Marcellus L. Joslyn, Deceased. Robert D. MacDonald v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974

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3Cited by57 opinions

  1. Reed v. RossSupreme Court of the United States · 1984
  2. Jerry W. Garrison v. D. J. McCarthy SuperintendentCourt of Appeals for the Ninth Circuit · 1981
  3. Snethen v. StateSupreme Court of Iowa · 1981
  4. Prado McGee Jr. v. W.J. Estelle, Jr., Director, Texas Department of Corrections, RespondentCourt of Appeals for the Fifth Circuit · 1984
  5. David Huffman v. Louie L. Wainwright, Secretary, the Department of Offender Rehabilitation, Etal.Court of Appeals for the Fifth Circuit · 1981

52 more not listed; retrieve them via the Exa API.

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