O'Nan v. Commissioner
United States Tax Court
Real estate was transferred by decedent to his wife, decedent retaining a life interest, pursuant to a predivorce property settlement agreement which was set forth and approved by the court in its divorce decree entered almost immediately thereafter. The wife was entitled to an equitable share in the husband's property, under the laws of the State of Kentucky, where the divorce was obtained.
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Real estate was transferred by decedent to his wife, decedent retaining a life interest, pursuant to a predivorce property settlement agreement which was set forth and approved by the court in its divorce decree entered almost immediately thereafter. The wife was entitled to an equitable share in the husband's property, under the laws of the State of Kentucky, where the divorce was obtained. Held, the transfer of such real estate to the wife was for an adequate and full consideration in money or money's worth within the meaning of sec. 2036, I.R.C. 1954, and the value thereof is not…
1Opinion of the Court
Estate of Morrison T. O'Nan, Deceased, Morrison A. O'Nan, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
O'Nan v. Commissioner
Docket No. 5803-64
United States Tax Court
47 T.C. 648; 1967 U.S. Tax Ct. LEXIS 130;
March 28, 1967, Filed
Decision will be entered under Rule 50.
Real estate was transferred by decedent to his wife, decedent retaining a life interest, pursuant to a predivorce property settlement agreement which was set forth and approved by the court in its divorce decree entered almost immediately thereafter. The wife was entitled to an equitable share in the…
2Cases cited46 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- United States v. DavisSupreme Court of the United States · 1962
- Merrill v. FahsSupreme Court of the United States · 1945
- Harris v. CommissionerSupreme Court of the United States · 1950
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