Legal Opinion

Estate of Courtney v. Commissioner

United States Tax Court

Decided June 18, 1974No. Docket No. 3984-73Published

Decedent and his wife purchased a residence in 1964 and financed it with a note for $ 38,000, secured by a deed of trust, payable to the First National Bank of Fort Worth. Shortly afterward, they deeded the residence to their son subject to the note and deed of trust. Decedent or his wife made all payments on the note prior to his death on May 1, 1969. Since his death all payments have been made by his wife.

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Decedent and his wife purchased a residence in 1964 and financed it with a note for $ 38,000, secured by a deed of trust, payable to the First National Bank of Fort Worth. Shortly afterward, they deeded the residence to their son subject to the note and deed of trust. Decedent or his wife made all payments on the note prior to his death on May 1, 1969. Since his death all payments have been made by his wife. The residence was not included as an asset in the decedent's gross estate, but half the outstanding balance on the note and one-half of one payment thereon were deducted as debts owed by…

1Opinion of the Court

Estate of Quintard Peters Courtney, Deceased, Quintard P. Courtney, Jr., and Will Allen Courtney, Co-Independent Executors, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Courtney v. Commissioner

Docket No. 3984-73

United States Tax Court

62 T.C. 317; 1974 U.S. Tax Ct. LEXIS 91; 62 T.C. No. 39;

June 18, 1974, Filed

Decision will be entered for the respondent.

Decedent and his wife purchased a residence in 1964 and financed it with a note for $ 38,000, secured by a deed of trust, payable to the First National Bank of Fort Worth. Shortly afterward, they deeded the residence to…

2Cases cited22 opinions

  1. Heiner v. TindleSupreme Court of the United States · 1928
  2. Mosells Silvey Pitner v. United StatesCourt of Appeals for the Fifth Circuit · 1967
  3. Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1929
  4. Estate of Hagmann v. CommissionerUnited States Tax Court · 1973
  5. Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963

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