Legal Opinion

Fisher v. Commissioner

United States Tax Court

Decided April 5, 1993No. Docket Nos. 9383-90, 9416-90, 9417-90UnpublishedCited by 3 opinions

Held: a cash lease to a member of the family of a qualified heir is a cessation of qualified use by the qualified heir, resulting in the imposition of the additional estate tax under I.R.C. sec. 2032A(c). Williamson v. Commissioner, 93 T.C. 242 (1989), affd. 974 F.2d 1525 (9th Cir. 1992), followed.

1Opinion of the Court

JACK FISHER, TRANSFEREE, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Fisher v. Commissioner

Docket Nos. 9383-90, 9416-90, 9417-90

United States Tax Court

T.C. Memo 1993-139; 1993 Tax Ct. Memo LEXIS 139; 65 T.C.M. (CCH) 2284;

April 5, 1993, Filed

Decisions will be entered under Rule 155.

Held: a cash lease to a member of the family of a qualified heir is a cessation of qualified use by the qualified heir, resulting in the imposition of the additional estate tax under I.R.C. sec. 2032A(c). Williamson v. Commissioner, 93 T.C. 242 (1989), affd. 974 F.2d 1525 (9th Cir. 1992),…

2Cases cited3 opinions

  1. Beryl P. Williamson v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
  2. Williamson v. CommissionerUnited States Tax Court · 1989
  3. Shaw v. CommissionerUnited States Tax Court · 1991

3Cited by3 opinions

  1. Stovall v. CommissionerUnited States Tax Court · 1993
  2. LeFever v. CommissionerUnited States Tax Court · 1994
  3. Stovall v. CommissionerUnited States Tax Court · 1993

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