Legal Opinion

Estate of Bloise v. Commissioner

United States Tax Court

Decided February 28, 1966No. Docket No. 4612-62Unpublished

Held, that since the petitioner failed to show that the decedent held stock under a parol trust for the benefit of his brothers and sisters, the fair market value of such stock is includable in the decedent's gross estate under either section 2033 or section 2035 of the Internal Revenue Code of 1954. Held, further, that the respondent did not err in disallowing a portion of the amount claimed by the estate as a deduction on account of the decedent's debt to a corporation.

1Opinion of the Court

Estate of Frank Bloise, Deceased, Nicholas Bloise, Executor, Aida B. Gabriele, Executrix v. Commissioner.

Estate of Bloise v. Commissioner

Docket No. 4612-62.

United States Tax Court

T.C. Memo 1966-44; 1966 Tax Ct. Memo LEXIS 238; 25 T.C.M. (CCH) 251; T.C.M. (RIA) 66044;

February 28, 1966

Held, that since the petitioner failed to show that the decedent held stock under a parol trust for the benefit of his brothers and sisters, the fair market value of such stock is includable in the decedent's gross estate under either section 2033 or section 2035 of the Internal Revenue Code of 1954. Held,…

2Cases cited4 opinions

  1. Aquilino v. United StatesSupreme Court of the United States · 1960
  2. Morgan v. CommissionerSupreme Court of the United States · 1940
  3. Van Sciver v. RothensiesCourt of Appeals for the Third Circuit · 1941
  4. Van Sciver v. RothensiesDistrict Court, E.D. Pennsylvania · 1941

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