Legal Opinion

McCall v. Commissioner

United States Board of Tax Appeals

Decided June 7, 1932No. Docket Nos. 47702-47705Published

Where subsequent to the filing and adjudication of a "first and final" account, but prior to the determination of a deficiency in estate taxes which respondent proposed to assess against the beneficiaries as transferees, other assets came into the hands of the executrix of an estate, which funds were more than sufficient to satisfy the deficiency in taxes determined by respondent and which funds remained undistributed in the estate up to and after the date of the notice of…

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Where subsequent to the filing and adjudication of a "first and final" account, but prior to the determination of a deficiency in estate taxes which respondent proposed to assess against the beneficiaries as transferees, other assets came into the hands of the executrix of an estate, which funds were more than sufficient to satisfy the deficiency in taxes determined by respondent and which funds remained undistributed in the estate up to and after the date of the notice of deficiency, respondent may not assess such deficiency against the beneficiaries as transferees.

1Opinion of the Court

FLORENCE MCCALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ELIZABETH K. NEWTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

RACHEL S. CHRISTOPHER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ISABEL K. J. GARRON, GORDON A. BLOCK AND WOODBURY TRUST COMPANY AS EXECUTORS OF THE ESTATE OF JOSEPH R. NEWTON, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

McCall v. Commissioner

Docket Nos. 47702-47705.

United States Board of Tax Appeals

26 B.T.A. 292; 1932 BTA LEXIS 1337;

June 7, 1932, Promulgated

Where subsequent to the filing and…

2Cases cited1 opinion

  1. McCall v. CommissionerUnited States Board of Tax Appeals · 1932

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