Estate of Buchholtz v. Commissioner
United States Tax Court
U.S. Treasury Bonds, qualified for use at par in payment of Federal estate taxes were included in decedent's gross estate in an amount exceeding the amounts required for payment of the estate tax as shown on the return, the deficiency in estate tax as previously determined, and the interest on such deficiency.
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U.S. Treasury Bonds, qualified for use at par in payment of Federal estate taxes were included in decedent's gross estate in an amount exceeding the amounts required for payment of the estate tax as shown on the return, the deficiency in estate tax as previously determined, and the interest on such deficiency. Held, such bonds having an aggregate par value sufficient to pay the total estate tax liability and any interest on the deficiency are includable in the gross estate at their par value. Held, further, petitioner is entitled to deduct, as an administration expense, the interest accrued…
1Opinion of the Court
OPINION
Tannenwald, Judge:
The dispute herein involves the Rule 155 computation mandated by the Court’s opinion (T.C. Memo. 1977-396). The principal issue before the Court is whether U. S. Treasury Bonds, included in decedent’s gross estate, should be valued at par to the extent of the interest on an estate tax deficiency. Both parties agree that such bonds are eligible under section 63121 for both the payment of the deficiency, resulting from the prior opinion of the Court and concessions by the parties, and the interest thereon. See Rev. Proc. 69-18, sec. 5.01, 1969-2 C.B. 300, 301. In the…
2Cases cited8 opinions
- Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Bankers Trust Company, as of the Will of Harriet Delta Ellis, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1960
- In Re Estate of Harry Fried, Deceased. Ethel Fried v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1971
- Estate of Fried v. CommissionerUnited States Tax Court · 1970
3 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Estate of Sachs v. CommissionerUnited States Tax Court · 1987
- Estate of Ruby Miller Whittle, Deceased, Citizens National Bank of Decatur, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1993
- In re Estate of MorganOhio Supreme Court · 1981
- Weld v. United StatesUnited States Court of Federal Claims · 1994
- Weld v. United StatesCourt of Appeals for the Federal Circuit · 1995
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