Estate of Michel v. Department of Taxation

We have recited only such of the facts as we deem necessary to be considered for a determination of the issue presented.

It appears from the contents of a note found in 5 A. L. R. (2d) 1122, that unless a peculiar factual situation exists so as to make both inapplicable, two rules have been followed in determining the effect of an agreement such as is present here upon the valuation of property made for the purpose of the assessment of an inheritance or estate tax. The so-called “federal rule” appears to be that the contract price determines the value; the so-called “Pennsylvania rule” is that…