Estate of Campbell v. Commissioner
United States Tax Court
Under the will of her husband, Tilman H. Campbell, who died a resident of Kentucky in July 1964, Martha Campbell was devised and bequeathed all of his property and estate, including a one-half interest in T. H. Campbell & Bros., a partnership, with complete and exclusive power to do with as she pleased and to convey, sell, or transfer all or any portion thereof.
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Under the will of her husband, Tilman H. Campbell, who died a resident of Kentucky in July 1964, Martha Campbell was devised and bequeathed all of his property and estate, including a one-half interest in T. H. Campbell & Bros., a partnership, with complete and exclusive power to do with as she pleased and to convey, sell, or transfer all or any portion thereof. Any portion of the estate left in her hands at the time of her death was to be divided equally between their three children, Edythe, George, and Jane. At the time of his death, Tilman's interest in the partnership was valued at $…
1Opinion of the Court
Bruce, Judge:
The Commissioner determined a deficiency in the gift tax of Martha K. Campbell for the year 1965 in the amount of $20,016.27 and an addition to tax under section 6651(a)(1)1 of $5,004.07. Petitioner is the administratrix of the Estate of Martha K. Campbell. The sole issue is whether Martha Campbell made a gift to her son George when she transferred to him an interest in the. partner-' ship T. H. Campbell & Bros, for $22,992.78.
FINDINGS OF FACT
Some facts have been stipulated and the stipulation of facts, together with the exhibits attached thereto, are incorporated by reference.
Mar…
2Cases cited11 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Adams v. CommissionerUnited States Tax Court · 1966
- Hanks v. McDanellCourt of Appeals of Kentucky (pre-1976) · 1948
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3Cited by4 opinions
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Estate of Campbell v. CommissionerUnited States Tax Court · 1972
- Saltzman v. CommissionerUnited States Tax Court · 1994