Legal Opinion
Estate of James A. Elkins, Jr., Margaret Elise Joseph and Leslie Keith Sasser, Independent Executors v. Commissioner
United States Tax Court
Decided March 11, 2013No. 16597-10Published
1Opinion of the Court
140 T.C. No. 5
UNITED STATES TAX COURT ESTATE OF JAMES A. ELKINS, JR., DECEASED, MARGARET ELISE JOSEPH AND LESLIE KEITH SASSER, INDEPENDENT EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16597-10. Filed March 11, 2013. D owned undivided fractional interests in 64 works of contemporary art. 1. Held: In valuing certain of those fractional interests, pursuant to I.R.C. sec. 2703(a)(2) we disregard D's agreement by which he waived his right to institute a partition action with respect to some of the works of art and thereby relinquished an important use of his…
2Cases cited28 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. CartwrightSupreme Court of the United States · 1973
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Parker v. CommissionerUnited States Tax Court · 1986
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