Safe Deposit & Trust Co. v. Commissioner
United States Board of Tax Appeals
1. In a proceeding brought by the executor, in his representative capacity, to contest a deficiency in estate tax, the Board may not consider whether he is personally answerable under Revised Statutes, § 3467. 2. Value of a large block of stock at the date of a decedent's death is not conclusively determined by the mathematical use of the unit price at which small lots were sold on the Stock Exchange, and evidence of other factors affecting value may be considered. 3. The…
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1. In a proceeding brought by the executor, in his representative capacity, to contest a deficiency in estate tax, the Board may not consider whether he is personally answerable under Revised Statutes, § 3467. 2. Value of a large block of stock at the date of a decedent's death is not conclusively determined by the mathematical use of the unit price at which small lots were sold on the Stock Exchange, and evidence of other factors affecting value may be considered. 3. The unpaid portion of a pledge to charity made in consideration of similar pledges by others, held deductible. Jeptha H. Wade,…
1Opinion of the Court
*260OPINION.
Steenhagen :
1. The petitioner seeks a determination in this proceeding that it is free from any “personal liability” which might be asserted under the Eevised Statutes, § 3467,1 because, acting under the Eevenue Act of 1926, section 313 (b),2 it made written applica*261tion to the Commissioner for the determination of the estate tax and discharge of its personal liability. The entire record in this proceeding establishes clearly that the deficiency has been determined against the estate and notice thereof sent to the petitioner in its representative capacity as executor. It has not been…
2Cases cited2 opinions
- Porter v. CommissionerSupreme Court of the United States · 1933
- Hulburd v. CommissionerSupreme Court of the United States · 1935
3Cited by35 opinions
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
- Estate of Meyer v. CommissionerUnited States Tax Court · 1972
- Estate of Theodore Geddings Tarver, Deceased, the Citizens and Southern National Bank of South Carolina v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Moore-McCormack Lines, Inc. v. CommissionerUnited States Tax Court · 1965
- Calder v. CommissionerUnited States Tax Court · 1985
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