Green v. Commissioner
United States Tax Court
Held, upon the facts, that there is no substantial reason for adjusting the discount factor of 4 per cent applied in accordance with the provisions of section 81.10 (i) of Regulations 105, in valuing the remainder interests involved in the instant case.
1Opinion of the Court
OPINION.
Fishek, Judge:
The question before us is whether or not, in the valuation of two remainder interests by the general method employed in section 81.10 (t) of Regulations 105, the discount factor of 4 per cent compounded annually, provided for in the regulations, should, upon the facts, be increased, and if so, by how much.
All of the facts are stipulated and are incorporated herein by reference except in the following respects: Paragraphs 18 and 19 of the stipulation refer to the value of the corpus of the trusts in question “at the death of the decedent.” Petitioner’s brief states that…
2Cases cited7 opinions
- In Re the Accounting of OsborneNew York Court of Appeals · 1913
- McMurtry v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Huntington Nat'l Bank v. CommissionerUnited States Tax Court · 1949
- Hanley v. United StatesUnited States Court of Claims · 1945
- Koshland's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
2 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Weller v. CommissionerUnited States Tax Court · 1962
- United States v. Howard Past, of the Estate of Edna C. Rosedale Ogg, DeceasedCourt of Appeals for the Ninth Circuit · 1965
- Pardee v. CommissionerUnited States Tax Court · 1967
- James Richard Bowden v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
- United States v. Richard S. Righter, of the Estate of Edna Beaham Mersereau, DeceasedCourt of Appeals for the Eighth Circuit · 1968
18 more not listed; retrieve them via the Exa API.