Estate of Hagmann v. Commissioner
United States Tax Court
At the time of his death, certain debts of the decedent constituted bona fide obligations of his estate. However, no claims were filed with respect to such debts against his estate, and such claims have not and will not be paid by the estate. Held, such claims are not deductible under sec. 2053(a)(3), I.R.C. 1954, in computing the net value of the estate.
1Opinion of the Court
Simpson, Judge:
The respondent determined a deficiency of $9,986.82 in the estate tax for the Estate of Frank G. Hagmann and an addition to tax under section 6651(a) of the Internal Revenue Code of 19541 of $2,496.71. The petitioner has conceded that she is liable for the addition to the tax under section 6651(a) to the extent of any deficiency that is due. Therefore, the only issue presented for decision is whether the estate is entitled to a deduction under section 2053(a) (3) for debts which were bona fide obligations at the date of the decedent’s death, but which have become unenforceable…
2Cases cited21 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Helvering v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1942
- Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1929
- Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- Shedd v. CommissionerUnited States Tax Court · 1961
16 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Estate of Sachs v. CommissionerUnited States Tax Court · 1987
- Estate of Van Horne v. CommissionerUnited States Tax Court · 1982
- Estate of Kyle v. CommissionerUnited States Tax Court · 1990
- Smith Ex Rel. Estate of Smith v. CommissionerCourt of Appeals for the Fifth Circuit · 1999
40 more not listed; retrieve them via the Exa API.