Legal Opinion

Estate of Wood v. Commissioner

United States Tax Court

Decided June 3, 1970No. Docket No. 6561-67Published

1. Held, income taxes incurred subsequent to the death of the transferee decedent by another taxable entity do not reduce the value of the interest of the within decedent in the prior estate under sec. 2033, I.R.C. 1954; nor are they deductible from the within decedent's gross estate under sec. 2053(a)(3), I.R.C. 1954. 2. Held, further, administration expenses deducted from the estate's Federal income taxes pursuant to an election under sec. 642(g), I.R.C. 1954, are not…

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1. Held, income taxes incurred subsequent to the death of the transferee decedent by another taxable entity do not reduce the value of the interest of the within decedent in the prior estate under sec. 2033, I.R.C. 1954; nor are they deductible from the within decedent's gross estate under sec. 2053(a)(3), I.R.C. 1954. 2. Held, further, administration expenses deducted from the estate's Federal income taxes pursuant to an election under sec. 642(g), I.R.C. 1954, are not available to reduce the "taxable estate" of the transferor for purposes of the computation of the credit for tax on prior…

1Opinion of the Court

Estate of Howard O. Wood, Jr., Manufacturers Hanover Trust Company, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Wood v. Commissioner

Docket No. 6561-67

United States Tax Court

54 T.C. 1180; 1970 U.S. Tax Ct. LEXIS 124;

June 3, 1970, Filed

Decision will be entered under Rule 50.

1. Held, income taxes incurred subsequent to the death of the transferee decedent by another taxable entity do not reduce the value of the interest of the within decedent in the prior estate under sec. 2033, I.R.C. 1954; nor are they deductible from the within decedent's gross estate under…

Also in this document: Concurrence.

2Cases cited10 opinions

  1. Burrow Trust v. CommissionerUnited States Tax Court · 1963
  2. Commissioner of Internal Revenue v. DavisCourt of Appeals for the First Circuit · 1943
  3. Haggart's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
  4. Haggart v. CommissionerUnited States Tax Court · 1949
  5. Gilruth v. CommissionerUnited States Tax Court · 1968

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