Legal Opinion

Farrell v. Commissioner

United States Tax Court

Decided June 8, 1949No. Docket No. 19764Published

Indebtedness originally incurred by decedent's son and evidenced by note upon which decedent eventually became maker, held, on the facts, to have continued to be son's indebtedness and, decedent being in the position of surety, held, further, not a deductible claim against petitioner estate, the son having acquired sufficient means by inheritance from another estate at decedent's death. Estate of Charles H. Lay, 40 B. T. A. 522, followed.

1Opinion of the Court

Estate of Margaret Ruth Brady Farrell, Deceased, Neile F. Towner, Central Hanover Bank and Trust Company, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent

Farrell v. Commissioner

Docket No. 19764

United States Tax Court

12 T.C. 962; 1949 U.S. Tax Ct. LEXIS 174;

June 8, 1949, Promulgated

Decision will be entered under Rule 50.

Indebtedness originally incurred by decedent's son and evidenced by note upon which decedent eventually became maker, held, on the facts, to have continued to be son's indebtedness and, decedent being in the position of surety, held, further, not a…

2Cases cited5 opinions

  1. Blanchard v. . BlanchardNew York Court of Appeals · 1911
  2. Coffey v. CommissionerUnited States Tax Court · 1943
  3. Harper v. CommissionerUnited States Tax Court · 1948
  4. Estate of Hamlin ex rel. Lincoln Rochester Trust Co. v. CommissionerUnited States Tax Court · 1947
  5. Farrell v. CommissionerUnited States Tax Court · 1949

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API