Brown v. Commissioner
United States Tax Court
Petitioner and Maude C. Brown, his wife, executed a joint will which contained reciprocal provisions. Upon Maude's death, the instrument, probated as her separate will, conveyed a life estate in her share of the community property to petitioner and the remainder therein to their sons.
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Petitioner and Maude C. Brown, his wife, executed a joint will which contained reciprocal provisions. Upon Maude's death, the instrument, probated as her separate will, conveyed a life estate in her share of the community property to petitioner and the remainder therein to their sons. Held: (1) That Maude's will did not put petitioner to an election which resulted in a transfer of the remainder interest in his community property at her death; (2) that petitioner did not intend the instrument by its terms to effect a present transfer of any interest in his share of the community property at…
1Opinion of the Court
S. E. Brown, Petitioner v. Commissioner of Internal Revenue, Respondent
Brown v. Commissioner
Docket No. 6578-66
United States Tax Court
52 T.C. 50; 1969 U.S. Tax Ct. LEXIS 158;
April 8, 1969, Filed
Decision will be entered for the petitioner.
Petitioner and Maude C. Brown, his wife, executed a joint will which contained reciprocal provisions. Upon Maude's death, the instrument, probated as her separate will, conveyed a life estate in her share of the community property to petitioner and the remainder therein to their sons. Held: (1) That Maude's will did not put petitioner to an election which…
2Cases cited44 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Nye v. BradfordTexas Supreme Court · 1946
- Schmitz v. CommissionerUnited States Tax Court · 1968
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