Legal Opinion

Petersen v. Commissioner

United States Tax Court

Decided March 22, 1961No. Docket Nos. 73870, 73871, 75864Published

Petitioner and his deceased wife were copartners in a ranching and cattle business. After her death, and during the administration of her estate, petitioner reported one-half of the income from the business, and decedent's estate the other half.

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Petitioner and his deceased wife were copartners in a ranching and cattle business. After her death, and during the administration of her estate, petitioner reported one-half of the income from the business, and decedent's estate the other half. Held: 1. Joint tenancy property passed to petitioner upon the death of his wife by right of survivorship, and all of the income therefrom is taxable to him. 2. Administration of this decedent's estate during the years here in issue was reasonable since substantial outstanding contested claims were pending. 3. During the proper period of administration…

1Opinion of the Court

Edwin M. Petersen, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Petersen v. Commissioner

Docket Nos. 73870, 73871, 75864

United States Tax Court

35 T.C. 962; 1961 U.S. Tax Ct. LEXIS 200;

March 22, 1961, Filed

Decisions will be entered under Rule 50.

Petitioner and his deceased wife were copartners in a ranching and cattle business. After her death, and during the administration of her estate, petitioner reported one-half of the income from the business, and decedent's estate the other half. Held:

1. Joint tenancy property passed to petitioner upon the death of his wife by…

2Cases cited23 opinions

  1. Tomaier v. TomaierCalifornia Supreme Court · 1944
  2. Siberell v. SiberellCalifornia Supreme Court · 1932
  3. Williams v. CommissionerUnited States Tax Court · 1951
  4. Schindler v. SchindlerCalifornia Court of Appeal · 1954
  5. Chick v. CommissionerUnited States Tax Court · 1946

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