Miller v. Commissioner
United States Tax Court
Petitioners and M entered into a written agreement whereby M agreed to leave her residence and certain furnishings to petitioners in her will, provided they would live with her and perform certain services for her for the remainder of her life. Petitioners carried out the agreement and decedent devised her residence and the furnishings to them.
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Petitioners and M entered into a written agreement whereby M agreed to leave her residence and certain furnishings to petitioners in her will, provided they would live with her and perform certain services for her for the remainder of her life. Petitioners carried out the agreement and decedent devised her residence and the furnishings to them. Held: The fair market value of the residence and furnishings is taxable to petitioners in the year of decedent's death as compensation for services rendered under sec. 61, I.R.C. 1954.
1Opinion of the Court
JESSE A. MILLER AND SIGNA H. MILLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Miller v. Commissioner
Docket No. 38309-85.
United States Tax Court
T.C. Memo 1987-271; 1987 Tax Ct. Memo LEXIS 271; 53 T.C.M. (CCH) 962; T.C.M. (RIA) 87271;
June 2, 1987.
Petitioners and M entered into a written agreement whereby M agreed to leave her residence and certain furnishings to petitioners in her will, provided they would live with her and perform certain services for her for the remainder of her life. Petitioners carried out the agreement and decedent devised her residence and the…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Morgan v. CommissionerSupreme Court of the United States · 1940
- United States v. MitchellSupreme Court of the United States · 1971
- Ethel West Cotnam v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Cotnam v. CommissionerUnited States Tax Court · 1957
6 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Estate of Dooley v. CommissionerUnited States Tax Court · 1992