Estate of Jenner v. Commissioner
United States Tax Court
Held: 1. Value, on decedent's death, of 226,800 shares of BF stock determined. 2. Value, on decedent's death, of 53,760 shares of CFC stock determined. 3. An underwriting discount in a firm commitment underwriting of stock is not an administrative expense deductible from decedent's gross estate under sec. 2053(a)(2), I.R.C. 1954.
1Opinion of the Court
ESTATE OF HELEN BAKER JENNER, Deceased, CONTINENTAL ILLINOIS NATIONAL BANK AND TRUST CO. OF CHICAGO, Executor, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Jenner v. Commissioner
Docket No. 1529-74.
United States Tax Court
T.C. Memo 1977-54; 1977 Tax Ct. Memo LEXIS 387; 36 T.C.M. (CCH) 241; T.C.M. (RIA) 770054;
March 3, 1977, Filed
Held: 1. Value, on decedent's death, of 226,800 shares of BF stock determined.
2. Value, on decedent's death, of 53,760 shares of CFC stock determined.
3. An underwriting discount in a firm commitment underwriting of stock is not an administrative…
2Cases cited7 opinions
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
- Estate of David Smith, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
- Estate of Heckscher v. CommissionerUnited States Tax Court · 1975
- In Re Estate of Marcellus L. Joslyn, Deceased. Robert D. MacDonald v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Collins v. AugerCourt of Appeals for the Eighth Circuit · 1978
- Zokoych v. SpaldingAppellate Court of Illinois · 1984
- Estate of Helen Baker Jenner, Deceased and Continental Illinois National Bank and Trust Company of Chicago v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978