Estate of Satz v. Commissioner
United States Tax Court
Decedent's former wife, Ruth, brought an action and obtained a judgment against decedent's estate for his failure to name her the beneficiary of certain life insurance policies. Her claim was premised on a separation agreement executed by Ruth and decedent which was incorporated into a divorce decree. Petitioner claims a deduction of $ 66,675.48 under sec. 2053, I.R.C. 1954, for funds paid to Ruth pursuant to the judgment.
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Decedent's former wife, Ruth, brought an action and obtained a judgment against decedent's estate for his failure to name her the beneficiary of certain life insurance policies. Her claim was premised on a separation agreement executed by Ruth and decedent which was incorporated into a divorce decree. Petitioner claims a deduction of $ 66,675.48 under sec. 2053, I.R.C. 1954, for funds paid to Ruth pursuant to the judgment. Held, petitioner is not entitled to a deduction under sec. 2053 merely because State law may have provided that the separation agreement operated as an equitable assignment…
1Opinion of the Court
Estate of Edward Satz, Deceased, Robert S. Goldenhersh, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Satz v. Commissioner
Docket No. 687-77
United States Tax Court
78 T.C. 1172; 1982 U.S. Tax Ct. LEXIS 70; 78 T.C. No. 82;
June 29, 1982, Filed
Decision will be entered for the respondent.
Decedent's former wife, Ruth, brought an action and obtained a judgment against decedent's estate for his failure to name her the beneficiary of certain life insurance policies. Her claim was premised on a separation agreement executed by Ruth and decedent which was incorporated into…
2Cases cited37 opinions
- Merrill v. FahsSupreme Court of the United States · 1945
- Harris v. CommissionerSupreme Court of the United States · 1950
- North v. NorthSupreme Court of Missouri · 1936
- Gardine v. CotteySupreme Court of Missouri · 1950
- Niederkorn v. NiederkornMissouri Court of Appeals · 1981
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