Legal Opinion

Estate of Salter v. Commissioner

United States Tax Court

Decided February 11, 1975No. Docket No. 8531-72PublishedCited by 7 opinions

Decedent Cary W. Salter, Sr., died on Mar. 1, 1968, leaving all of his property to his surviving widow, Medora L. Salter, with any "residual after her death" to his three children in equal parts.

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Decedent Cary W. Salter, Sr., died on Mar. 1, 1968, leaving all of his property to his surviving widow, Medora L. Salter, with any "residual after her death" to his three children in equal parts. Before the estate tax return was due, the widow filed a "Petition To Construe Will" in the local Chancery Court, seeking an order interpreting the will to give her an absolute power to appoint the estate during her lifetime without the necessity for any remaindermen joining with her in the conveyance thereof. The children filed entries of appearance, joined in the petition, and agreed to be bound by…

1Opinion of the Court

OPINION

Featherston, Judge:

Respondent determined that the Estate of Medora L. Salter, non compos mentis, is liable as transferee for a deficiency of $22,552.99 in the estate tax due from the estate of Cary W. Salter, Sr. (hereinafter sometimes referred to as decedent). Petitioner acknowledges that it is transferee of the assets of the estate of Cary W. Salter, Sr., within the meaning of sections 6324 and 6901,1 but alleges that respondent erred in determining a deficiency in the estate tax of decedent’s estate. Other issues having been settled, one issue remains: Whether a bequest in…

2Cases cited27 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Estate of Edward F. Pipe, Deceased, Nettie M. Pipe v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  3. Pipe v. CommissionerUnited States Tax Court · 1954
  4. Brown v. RoutzahnCourt of Appeals for the Sixth Circuit · 1933
  5. Bel v. United StatesCourt of Appeals for the Fifth Circuit · 1971

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

3Cited by7 opinions

  1. Estate of Neugass v. CommissionerUnited States Tax Court · 1975
  2. Estate of Salter v. CommissionerCourt of Appeals for the Fifth Circuit · 1977
  3. Estate Of Medora L. SalterCourt of Appeals for the Fifth Circuit · 1977
  4. Estate of Goree v. CommissionerUnited States Tax Court · 1994
  5. Estate of Neugass v. CommissionerUnited States Tax Court · 1975

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

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