Hull v. Commissioner
United States Tax Court
1. Decedent, who died February 2, 1957, was the senior partner in a law partnership. Under the terms of the partnership agreement the estate of a deceased partner was entitled to receive a share of the net income of the partnership for several years after his death.
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1. Decedent, who died February 2, 1957, was the senior partner in a law partnership. Under the terms of the partnership agreement the estate of a deceased partner was entitled to receive a share of the net income of the partnership for several years after his death. Held, the value of this right was includible in decedent's gross estate for estate tax purposes. 2. An amendment to the partnership agreement reducing the share of a deceased partner's estate in future net income was executed on the date of decedent's death by all partners except decedent. Several months after decedent's death the…
1Opinion of the Court
Drennen, Judge:
Respondent determined a deficiency in estate tax against petitioner (Estate of Arthur H. Hull) in the amount of $56,987.32. The issues remaining for decision are:(1) Whether Arthur H. Hull’s gross estate for Federal estate tax purposes should be increased by the value of his estate’s right to receive a share of partnership income subsequent to his death; and, if so(2) Whether respondent correctly determined the value of this right at the alternate valuation date;(3) Whether Arthur H. Hull’s transfer of 15 life insurance policies within 3 years of his death was made “in…
2Cases cited39 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- United States v. BessSupreme Court of the United States · 1958
- United States v. WellsSupreme Court of the United States · 1931
- Lyeth v. HoeySupreme Court of the United States · 1938
34 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Estate of Coleman v. CommissionerUnited States Tax Court · 1969
- Estate of Curry v. CommissionerUnited States Tax Court · 1980
- Estate of Rowan v. CommissionerUnited States Tax Court · 1970
- Estate of Honickman v. CommissionerUnited States Tax Court · 1972
- Porter v. CommissionerUnited States Tax Court · 1967
16 more not listed; retrieve them via the Exa API.