Estate of Whittle v. Commissioner
United States Tax Court
On the death of H, practically all of the property included in his gross estate passed to W as surviving joint tenant with the result that there was no probate estate. W caused H's estate to elect to defer the payment of the estate tax under sec. 6166, I.R.C.
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On the death of H, practically all of the property included in his gross estate passed to W as surviving joint tenant with the result that there was no probate estate. W caused H's estate to elect to defer the payment of the estate tax under sec. 6166, I.R.C. Upon W's death, respondent claimed that, in computing the credit for taxes on prior transfers under sec. 2013, I.R.C., the value of such property should be reduced by the liability for interest on such deferral (all of which had been paid) in arriving at the net value of the property transferred. Held, the liability for interest in the…
1Opinion of the Court
ESTATE OF RUBY MILLER WHITTLE, DECEASED, CITIZENS NATIONAL BANK OF DECATUR, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JOHN G. AND RUBY M. WHITTLE TRUST DATED 3/17/1981, CITIZENS NATIONAL BANK OF DECATUR, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Whittle v. Commissioner
Docket Nos. 13171-89, 21508-89
United States Tax Court
97 T.C. 362; 1991 U.S. Tax Ct. LEXIS 84; 97 T.C. No. 25;
September 19, 1991, Filed
Decisions will be entered for the petitioners.
On the death of H, practically all of the property included in his gross estate passed…
2Cases cited16 opinions
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Estate of Bailly v. CommissionerUnited States Tax Court · 1983
- Groetzinger v. CommissionerUnited States Tax Court · 1977
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