Legal Opinion

Estate of Denbigh ex rel. Denbigh v. Commissioner

United States Tax Court

Decided July 23, 1946No. Docket No. 8317PublishedCited by 22 opinions

1Opinion of the Court

OPINION.

Murdock, Judge:

The petitioner asks only that the Commissioner be reversed in increasing the values of the three contracts over the amount reported on the return. His pleadings do not ask that the values be reduced below the amounts returned. It is just as well that this is so, because the record does not establish any specific values for the contracts as of July 24,1943.

The question narrows to this, Must the life expectancy as shown by standard expectancy tables for a female of the age of this annuitant be used in valuing these contracts, or may the fact that her actual life…

2Cases cited4 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. Vicksburg & Meridian Railroad v. PutnamSupreme Court of the United States · 1886
  3. United States v. Provident Trust Co.Supreme Court of the United States · 1934
  4. Simpson v. United StatesSupreme Court of the United States · 1920

3Cited by22 opinions

  1. Huntington Nat'l Bank v. CommissionerUnited States Tax Court · 1949
  2. Jennings v. CommissionerUnited States Tax Court · 1948
  3. Butler v. CommissionerUnited States Tax Court · 1952
  4. Continental Illinois National Bank and Trust Company of Chicago, as of the Estate of Josephine W. Speth, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1974
  5. Darling v. CommissionerUnited States Tax Court · 1965

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