Estate of Kelley v. Commissioner
United States Tax Court
Held, transactions whereby J. W. Kelley and Margaret I. Kelley, in 1954, transferred to their children and grandchildren remainder interests in certain land in consideration of notes secured by vendor's liens were gifts within the meaning of sec. 1000, I.R.C. 1939, only to the extent that the value of the transferred interests exceeded the amount of the notes. Held, further, the additions to the tax determined under sec. 6651(a), I.R.C. 1954, are not applicable.
1Opinion of the Court
Estate of J. W. Kelley, Deceased, N. Ray Kelley, Independent Executor, Petitioner v. Commissioner of Internal Revenue, Respondent; Margaret I. Kelley, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Kelley v. Commissioner
Docket Nos. 3236-73, 3237-73
United States Tax Court
63 T.C. 321; 1974 U.S. Tax Ct. LEXIS 11;
December 12, 1974, Filed
Decisions will be entered under Rule 155. 9
Held, transactions whereby J. W. Kelley and Margaret I. Kelley, in 1954, transferred to their children and grandchildren remainder interests in certain land in consideration of notes secured by…
2Cases cited7 opinions
- Commissioner of Internal Revenue v. Van VorstCourt of Appeals for the Ninth Circuit · 1932
- Story v. CommissionerUnited States Tax Court · 1962
- Van Vorst v. CommissionerUnited States Board of Tax Appeals · 1931
- Estate of Kelley v. CommissionerUnited States Tax Court · 1974
- Haygood v. CommissionerUnited States Tax Court · 1964
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