Harper v. Commissioner
United States Tax Court
H died testate. Among the assets of her estate were notes executed by T and G and by G and his wife, some of which were secured by stock. The value of the stock plus the net worth of the makers was less than the face amount of the notes at time of H's death. Under will of H, T and G each became entitled to receive one-sixth of her residuary estate. Except for these inheritances, there existed no reasonable expectation that the makers of the notes could pay their obligations.
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H died testate. Among the assets of her estate were notes executed by T and G and by G and his wife, some of which were secured by stock. The value of the stock plus the net worth of the makers was less than the face amount of the notes at time of H's death. Under will of H, T and G each became entitled to receive one-sixth of her residuary estate. Except for these inheritances, there existed no reasonable expectation that the makers of the notes could pay their obligations. If inheritances are reflected in net worth of the makers, they become financially able to pay them. Respondent…
1Opinion of the Court
Estate of Elizabeth V. Harper, Deceased, Genesee Valley Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Harper v. Commissioner
Docket No. 15948
United States Tax Court
11 T.C. 717; 1948 U.S. Tax Ct. LEXIS 43;
October 29, 1948, Promulgated
Decision will be entered under Rule 50.
H died testate. Among the assets of her estate were notes executed by T and G and by G and his wife, some of which were secured by stock. The value of the stock plus the net worth of the makers was less than the face amount of the notes at time of H's death. Under will of H, T and G each…
2Cases cited4 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Walker v. CommissionerUnited States Tax Court · 1944
- Harper v. CommissionerUnited States Tax Court · 1948
- Hodge v. CommissionerUnited States Tax Court · 1943