Legal Opinion

Gumm v. Commissioner

United States Tax Court

Decided October 11, 1989No. Docket Nos. 12065-85, 12586-85Published

Real property of an estate was distributed to petitioners, and the estate, if not already insolvent, was rendered insolvent by the distribution. Held, petitioners are liable under sec. 6901, I.R.C. 1954, as amended, as transferees for the Federal estate tax liability of the estate.

1Opinion of the Court

Nancy J. Gumm, aka Nancy J. Gumm Errichetti, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent; Ellen Gumm Bailey, Formerly Known As Ellen Gumm Reuben, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent

Gumm v. Commissioner

Docket Nos. 12065-85, 12586-85

United States Tax Court

93 T.C. 475; 1989 U.S. Tax Ct. LEXIS 132; 93 T.C. No. 38;

October 11, 1989October 11, 1989, Filed

Decisions will be entered for the respondent.

Real property of an estate was distributed to petitioners, and the estate, if not already insolvent, was rendered insolvent by the…

2Cases cited32 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
  3. Kreps v. CommissionerUnited States Tax Court · 1964
  4. Leach v. CommissionerUnited States Tax Court · 1953
  5. Carolyn Brafman v. United StatesCourt of Appeals for the Fifth Circuit · 1967

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