Dickson v. Commissioner
United States Tax Court
Estate Tax -- Gross Estate -- Value -- Unrecognized Interest. -- Full value of an interest included in gross estate, although existence not recognized at date of death, where never disputed although Orphans' Court had not recognized it in prior accountings but the courts recognized it when later first brought to their attention.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $57,476.34 in estate tax. The only issue is as to the value for estate tax purposes of the decedent’s one-tenth remainder interest in the corpus of a trust established under the will of her mother. The parties have filed a stipulation of facts and in addition the petitioner offered the opinions of two lawyers as to value.
The decedent died on March 30, 1944. The estate tax return was filed with the collector of internal revenue for the twenty-third district of Pennsylvania.
Eliza Thaw Edwards died a resident of Pennsylvania on…
2Cases cited12 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Estate of Spiegel v. CommissionerSupreme Court of the United States · 1949
- Overbrook Heights Building & Loan Ass'n v. WilsonSupreme Court of Pennsylvania · 1939
- Bache's EstateSupreme Court of Pennsylvania · 1914
7 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Porter v. CommissionerUnited States Tax Court · 1967
- Hagenlocher v. CommissionerUnited States Tax Court · 1964
- Dickson v. CommissionerUnited States Tax Court · 1949
- Hagenlocher v. CommissionerUnited States Tax Court · 1964
- Porter v. CommissionerUnited States Tax Court · 1967