Estate of Saunders v. Comm'r
United States Tax Court
Decedent's estate claimed a deduction of $30 million in relation to litigation pending against the estate at the date of death. The case was submitted on stipulated facts and an offer of proof for a preliminary determination as to whether the amount of the claim was ascertainable with reasonable certainty and deductible as of the date of death, in accordance with sec. 20.2053-1(b)(3), Estate Tax Regs.
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Decedent's estate claimed a deduction of $30 million in relation to litigation pending against the estate at the date of death. The case was submitted on stipulated facts and an offer of proof for a preliminary determination as to whether the amount of the claim was ascertainable with reasonable certainty and deductible as of the date of death, in accordance with sec. 20.2053-1(b)(3), Estate Tax Regs. Held: Different standards apply to including a claim in favor of an estate in the gross estate and deducting a claim against an estate for estate tax purposes. Held, further, as demonstrated by…
1Opinion of the Court
ESTATE OF GERTRUDE H. SAUNDERS, DECEASED, WILLIAM W. SAUNDERS, JR., AND RICHARD B. RIEGELS, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Saunders v. Comm'r
Docket No. 10957-09.
United States Tax Court
136 T.C. 406; 2011 U.S. Tax Ct. LEXIS 21; 136 T.C. No. 18;
April 28, 2011, Filed
Decision will be entered under Rule 155.
Decedent's estate claimed a deduction of $30 million in relation to litigation pending against the estate at the date of death. The case was submitted on stipulated facts and an offer of proof for a preliminary determination as to whether the…
2Cases cited24 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Harry S. Stonehill and Robert P. Brooks v. United StatesCourt of Appeals for the Ninth Circuit · 1969
- United States v. StonehillCourt of Appeals for the Ninth Circuit · 1983
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