Legal Opinion

Loveland v. Commissioner

United States Tax Court

Decided July 6, 1949No. Docket No. 16924Published

Estate Tax -- Jointly Held Property -- Money Consideration -- Section 811 (e) (1). -- A wife did not acquire her interest in jointly held property from her husband for a full and adequate consideration in money or money's worth within the meaning of section 811 (e) (1), where she nursed her husband for 48 years and he had agreed she should have $ 12.50 per week for her services to him.

1Opinion of the Court

Estate of Harold Loveland, Hattie F. Loveland, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent

Loveland v. Commissioner

Docket No. 16924

United States Tax Court

13 T.C. 5; 1949 U.S. Tax Ct. LEXIS 134;

July 6, 1949, Promulgated

Decision will be entered for the respondent.

Estate Tax -- Jointly Held Property -- Money Consideration -- Section 811 (e) (1). -- A wife did not acquire her interest in jointly held property from her husband for a full and adequate consideration in money or money's worth within the meaning of section 811 (e) (1), where she nursed her husband for 48…

2Cases cited4 opinions

  1. Commissioner v. WemyssSupreme Court of the United States · 1945
  2. Merrill v. FahsSupreme Court of the United States · 1945
  3. Bergan v. CommissionerUnited States Tax Court · 1943
  4. Loveland v. CommissionerUnited States Tax Court · 1949

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