Estate of Boyd v. Commissioner
United States Tax Court
Decedent's gross estate consisted of probate and nonprobate assets. The nonprobate assets included life insurance proceeds on decedent's life, payable to decedent's son. Decedent's will directed the estate's representatives to pay all Federal estate and State inheritance taxes imposed upon the gross estate, including tax imposed upon nonprobate property. Decedent's son, the sole beneficiary under the will, disclaimed his testate and intestate interests.
Read the full summary
Decedent's gross estate consisted of probate and nonprobate assets. The nonprobate assets included life insurance proceeds on decedent's life, payable to decedent's son. Decedent's will directed the estate's representatives to pay all Federal estate and State inheritance taxes imposed upon the gross estate, including tax imposed upon nonprobate property. Decedent's son, the sole beneficiary under the will, disclaimed his testate and intestate interests. The net probate estate passed by intestacy to decedent's surviving spouse and qualified for a marital deduction. Held: Decedent's son, the…
1Opinion of the Court
Sterrett, Chief Judge-.
Respondent determined a deficiency by notice dated October 5, 1982, of $34,497.04 in the Federal estate tax of petitioner. Respondent’s amended answer determined an additional deficiency of $8,468.06. The deficiencies are based on reductions of the estate marital deduction.
After concessions, the primary issue for decision is whether the beneficiary of nonprobate life insurance proceeds was liable to the executor of the estate for payment of Federal estate tax attributable to the insurance proceeds. Also at issue is whether the marital deduction must be reduced for State…
2Cases cited18 opinions
- Riggs v. Del DragoSupreme Court of the United States · 1942
- Nunnemacher v. StateWisconsin Supreme Court · 1906
- Uihlein v. UihleinWisconsin Supreme Court · 1953
- Estate of StephensonWisconsin Supreme Court · 1920
- Adele H. Dodd and William A. Dodd, Executors of the Estate of John A. Dodd, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1965
13 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Estate of Boyd v. CommissionerUnited States Tax Court · 1985
- Estate of Edward A. Boyd by Julia H. Boyd and Michael E. Boyd, Co-Personal Representatives v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987