Legal Opinion

Estate of Moss v. Commissioner

United States Tax Court

Decided September 15, 1980No. Docket No. 10949-76Published

Decedent sold stock and property for which he received promissory notes as payment. The notes contained a cancellation clause providing that the principal and interest due under the notes would be extinguished on decedent's death. The sale was made at arm's length for adequate and full consideration. Held, the notes are not to be included in decedent's gross estate.

1Opinion of the Court

Estate of John A. Moss, Deceased, Bank of Clearwater, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Moss v. Commissioner

Docket No. 10949-76

United States Tax Court

74 T.C. 1239; 1980 U.S. Tax Ct. LEXIS 65;

September 15, 1980, Filed

Decision will be entered under Rule 155.

Decedent sold stock and property for which he received promissory notes as payment. The notes contained a cancellation clause providing that the principal and interest due under the notes would be extinguished on decedent's death. The sale was made at arm's length for adequate and…

2Cases cited10 opinions

  1. Crooks v. HarrelsonSupreme Court of the United States · 1930
  2. Fidelity-Philadelphia Trust Co. v. SmithSupreme Court of the United States · 1958
  3. Bergan v. CommissionerUnited States Tax Court · 1943
  4. Buckwalter v. CommissionerUnited States Tax Court · 1966
  5. United States v. Ashby O. Stewart, of the Last Will and Testament of Mary W. Stewart, DeceasedCourt of Appeals for the Ninth Circuit · 1959

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