Sohosky v. Commissioner
United States Tax Court
When X died his estate consisted largely of stock of a family corporation. By the terms of his will, his widow received the stock -- "for and during her life, with full power to sell or dispose of all or any part thereof as she may see fit during her lifetime." Some time after X's death, his widow transferred her interest in the stock to her sons (petitioners herein). Held, the sons purchased the entire interest in the stock and not just a life estate therein.
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When X died his estate consisted largely of stock of a family corporation. By the terms of his will, his widow received the stock -- "for and during her life, with full power to sell or dispose of all or any part thereof as she may see fit during her lifetime." Some time after X's death, his widow transferred her interest in the stock to her sons (petitioners herein). Held, the sons purchased the entire interest in the stock and not just a life estate therein. Therefore, as the stock was an intangible asset with an unlimited, or not reasonably ascertainable, useful life, petitioners are not…
1Opinion of the Court
Henry W. Sohosky and Donna Sohosky, Petitioners v. Commissioner of Internal Revenue, Respondent; John J. Sohosky, Jr., and M. Jean Sohosky, Petitioners v. Commissioner of Internal Revenue, Respondent
Sohosky v. Commissioner
Docket Nos. 4162-70, 4239-70
United States Tax Court
57 T.C. 403; 1971 U.S. Tax Ct. LEXIS 7;
December 20, 1971, Filed
Decisions will be entered for the respondent.
When X died his estate consisted largely of stock of a family corporation. By the terms of his will, his widow received the stock -- "for and during her life, with full power to sell or dispose of all or any part…
2Cases cited24 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Estate of Christ v. Comm'rUnited States Tax Court · 1970
- Housman v. LewellenSupreme Court of Missouri · 1951
- Garland v. SmithSupreme Court of Missouri · 1901
- Burnet v. BurnetSupreme Court of Missouri · 1912
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