Estate of Sparling v. Commissioner
United States Tax Court
Decedent's husband died leaving his portion of community property to a testamentary trust. Under the terms of his will decedent could elect to have her share of the community property pass into the testamentary trust. If she so elected, she would receive for her life the income from the entire corpus of the trust. Furthermore, when decedent died she held participating 10-year life agreements in ISTF, an open-end, diversified management company.
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Decedent's husband died leaving his portion of community property to a testamentary trust. Under the terms of his will decedent could elect to have her share of the community property pass into the testamentary trust. If she so elected, she would receive for her life the income from the entire corpus of the trust. Furthermore, when decedent died she held participating 10-year life agreements in ISTF, an open-end, diversified management company. Petitioner valued these agreements for estate tax purposes at their liquidation value. Held, participating agreement shares in open-end investment…
1Opinion of the Court
Estate of Isabelle M. Sparling, Deceased, Crocker-Citizens National Bank, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Sparling v. Commissioner
Docket Nos. 1307-70, 1309-70
United States Tax Court
60 T.C. 330; 1973 U.S. Tax Ct. LEXIS 113; 60 T.C. No. 40;
June 5, 1973, Filed
Decisions will be entered under Rule 50.
Decedent's husband died leaving his portion of community property to a testamentary trust. Under the terms of his will decedent could elect to have her share of the community property pass into the testamentary trust. If she so elected, she would receive…
2Cases cited44 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- United States v. CartwrightSupreme Court of the United States · 1973
- United States v. PelzerSupreme Court of the United States · 1941
- Jackson v. United StatesSupreme Court of the United States · 1964
- Estate of Christ v. Comm'rUnited States Tax Court · 1970
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