Ingalls v. Commissioner
United States Tax Court
In 1957 petitioner reported on her gift tax return one-half of the gifts made by her husband in August 1957 and claimed her entire $ 30,000 specific exemption. Her husband died in November 1957. In 1958 petitioner made gifts to her children and grandchildren.
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In 1957 petitioner reported on her gift tax return one-half of the gifts made by her husband in August 1957 and claimed her entire $ 30,000 specific exemption. Her husband died in November 1957. In 1958 petitioner made gifts to her children and grandchildren. Respondent determined that one-half of the gifts made by petitioner's husband in 1957 were made in contemplation of death and included the value thereof in his gross estate in determining his estate tax giving a credit against that tax for the gift tax paid with respect to the amounts included in the gross estate. Had petitioner's…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioner’s gift tax for the year 1958 in the amount of $10,237.50. A question of the valuation of stock raised by the pleadings has been disposed of by the parties by stipulation, leaving for our decision the following issues:(1) Is petitioner entitled to deduct in computing lier gift tax for 1958 all or any portion of her $30,000 specific gift tax exemption, even though this entire exemption was claimed on her gift tax return for 1957 reporting one-half of her husband’s gifts made prior to his death on November 23,1957, where, as a…
2Cases cited7 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Heiner v. DonnanSupreme Court of the United States · 1932
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Basket v. HassellSupreme Court of the United States · 1883
- Lockard v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
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3Cited by9 opinions
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
- English v. United StatesDistrict Court, N.D. Florida · 1968
- Norair v. CommissionerUnited States Tax Court · 1976
- Estate of Gawne v. CommissionerUnited States Tax Court · 1983
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
4 more not listed; retrieve them via the Exa API.