Hartshorne v. Commissioner
United States Tax Court
Held, (1) the Bar Harbor property is includable in decedent's gross estate at a value of $ 10,000, and (2) petitioners have failed to prove that there was adequate and full consideration in money or money's worth for the remainder interest of the testamentary trust created by paragraph Third A of decedent's will, and such remainder interest in the amount of $ 184,341.33 is not deductible as a claim against the decedent's estate under sec. 2053 of the Internal Revenue Code of…
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Held, (1) the Bar Harbor property is includable in decedent's gross estate at a value of $ 10,000, and (2) petitioners have failed to prove that there was adequate and full consideration in money or money's worth for the remainder interest of the testamentary trust created by paragraph Third A of decedent's will, and such remainder interest in the amount of $ 184,341.33 is not deductible as a claim against the decedent's estate under sec. 2053 of the Internal Revenue Code of 1954.
1Opinion of the Court
Arundell, Judge:
Respondent determined a deficiency in estate tax in the amount of $184,563.60 in respect of the Estate of Harold Hartshorne. Petitioners assign three errors as follows:
A. In valuing decedents one-half interest in real property located in Bar Harbor, Maine, at $10,000.00, whereas th'e true value of said interest was $7,021.49.
B. In disallowing as a deduction to the extent of $231,496.38 the obligation or debt of the estate created by Separation Agreement dated January 1, 1942 between decedent and Mary Bryan Hartshorne.
C. In disallowing as a deduction the further amount of…
2Cases cited9 opinions
- Harris v. CommissionerSupreme Court of the United States · 1950
- Rosenthal v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Glen v. CommissionerUnited States Tax Court · 1966
- Sanford D. Beecher and William White, Jr., Executors of the Estate of John Richard Geary v. United StatesCourt of Appeals for the Third Circuit · 1960
- Hooker v. CommissionerUnited States Tax Court · 1948
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of D'Ambrosio v. CommissionerUnited States Tax Court · 1995
- Spruance v. CommissionerUnited States Tax Court · 1973
- Estate of Fenton v. CommissionerUnited States Tax Court · 1978
- ESTATE OF HUNTINGTON v. COMMISSIONERUnited States Tax Court · 1993
- Estate of Gibson v. CommissionerUnited States Tax Court · 1976
8 more not listed; retrieve them via the Exa API.