Campana v. Commissioner of Revenue

In filing a Massachusetts estate tax return for the estate of his mother, Richard A. Campana (acting as executor) excluded from the gross estate her dwelling house in Wellesley for the reason (disclosed in the return) that, prior to her death in 1982, he had acquired a joint survivorship interest in that real estate for valuable consideration. The Commissioner of Revenue determined that Campana had not come into the joint tenancy for money or money’s worth and assessed a tax deficiency of $13,844.30.

After the commissioner failed to act on an application for abatement, Campana, conformably…