Estate of Meyer v. Commissioner
United States Tax Court
A, B, and C died in 1975 each leaving property to D. A's, B's, and C's estates paid estate taxes attributable to the properties transferred to D in the respective amounts of $ 2,435.25, $ 168,199.50, and $ 2,474.90. D's estate tax attributable to A's, B's, and C's property is $ 10,156.71, $ 126,622.76, and $ 25,132.41, respectively.
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A, B, and C died in 1975 each leaving property to D. A's, B's, and C's estates paid estate taxes attributable to the properties transferred to D in the respective amounts of $ 2,435.25, $ 168,199.50, and $ 2,474.90. D's estate tax attributable to A's, B's, and C's property is $ 10,156.71, $ 126,622.76, and $ 25,132.41, respectively. Held, sec. 20.2013-6, Estate Tax Regs., is valid, and D's credit for Federal estate tax on prior transfers under sec. 2013, I.R.C. 1954, is computed separately for each transferor.
1Opinion of the Court
Wiles, Judge:
Respondent determined a deficiency in dece- . dent’s Federal estate tax in the amount of $41,001.01. After concessions, the sole issue for decision is whether, when there are two or more transferors,, the credit for Federal estate tax on prior, transfers under section 20131 is to be computed separately with respect to the property received from each transferor.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Anna-Marie Meyer (hereinafter decedent) died on January 28, 1978. Edwin L. Meyer, Jr., Executor, resided in Durham, NC, at the time he filed…
2Cases cited4 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
3Cited by3 opinions
- Rabenold v. CommissionerUnited States Tax Court · 1985
- Estate of Anna Marie Meyer, Edwin L. Meyer, Jr., Petitioner v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1985
- Estate of Meyer v. CommissionerUnited States Tax Court · 1984