Estate of Holding v. Commissioner
United States Tax Court
Decedent, Maggie M. Holding, in 1952 and for several years prior thereto, owned some valuable unimproved land near the city of Raleigh, North Carolina. She sold it that year at what she considered an advantageous price. She gave part of the proceeds of the sale to her children, grandchildren, and a daughter-in-law who had remarried subsequent to her husband's death.
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Decedent, Maggie M. Holding, in 1952 and for several years prior thereto, owned some valuable unimproved land near the city of Raleigh, North Carolina. She sold it that year at what she considered an advantageous price. She gave part of the proceeds of the sale to her children, grandchildren, and a daughter-in-law who had remarried subsequent to her husband's death. Although the donor was 87 years of age she was in good health at the time the gifts were made and the dominant motive of the donor in making the gifts was the satisfaction of seeing her children, grandchildren, and daughter-in-law…
1Opinion of the Court
The Commissioner has determined a deficiency in the estate tax of the Estate of Maggie M. Holding of $15,645.55. The deficiency is due to the addition to the estate reported on the return of $61,000 explained in the deficiency notice, as follows :
Explanation oar Adjustments
Schedule G
Gifts made in 1952 and 1953 to Returned Determined
Willis Holding, Jr-_ $0.00 $11, 000. 00
Bernice Y. Holding_ _ 0. 00 3, 000.00
John N. Holding_ _ 0.00 11,000.00
Doris M. Holding_ _ 0. 00 3, 000. 00
H. Jerome Stockard_ _ 0.00 11,000.00
Gene M. Stockard, Jr-_ 0.00 3,000.00
Mildred H. Stockard_ _ 0.00 9, 000.00
H. Jerome…
2Cases cited3 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Levi v. United StatesUnited States Court of Claims · 1936
- Bradley v. SmithCourt of Appeals for the Seventh Circuit · 1940
3Cited by5 opinions
- Estate of Lidbury v. CommissionerUnited States Tax Court · 1985
- Hoover v. United StatesUnited States Court of Claims · 1960
- Estate of Holding v. CommissionerUnited States Tax Court · 1958
- Estate of Lidbury v. CommissionerUnited States Tax Court · 1985
- Estate of Malone v. CommissionerUnited States Tax Court · 1976