Legal Opinion

Estate of Curry v. Commissioner

United States Tax Court

Decided June 9, 1980No. Docket No. 9502-76Published

Pursuant to an agreement entered into prior to decedent's death, P, an estate, had the right to participate in a percentage of any contingent fees subsequently awarded in 13 pending Indian claims cases.

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Pursuant to an agreement entered into prior to decedent's death, P, an estate, had the right to participate in a percentage of any contingent fees subsequently awarded in 13 pending Indian claims cases. Past experience and an analysis of the cases involved (both as to their nature and the stage of the proceedings reached at the date of death), as well as other factors, indicated that the claims had significant value, although estimates of this value were subject to substantial imprecision. Held: Under secs. 2031 and 2033, I.R.C. 1954, the term "property" encompasses choses in action,…

1Opinion of the Court

Estate of James E. Curry, Deceased, Aileen Curry-Cloonan and Beulah Bullard, Coexecutrices, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Curry v. Commissioner

Docket No. 9502-76

United States Tax Court

74 T.C. 540; 1980 U.S. Tax Ct. LEXIS 118;

June 9, 1980, Filed

Decision will be entered under Rule 155.

Pursuant to an agreement entered into prior to decedent's death, P, an estate, had the right to participate in a percentage of any contingent fees subsequently awarded in 13 pending Indian claims cases. Past experience and an analysis of the cases involved (both as to their…

2Cases cited15 opinions

  1. Bull v. United StatesSupreme Court of the United States · 1935
  2. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  3. Burnet v. LoganSupreme Court of the United States · 1931
  4. Estate of Smith v. CommissionerUnited States Tax Court · 1972
  5. Estate of David Smith, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975

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