Legal Opinion

Estate of Vahlteich v. Commissioner

United States Tax Court

Decided April 18, 1994No. Docket No. 13655-92Unpublished

D's estate included a QTIP trust that was formed by D's deceased wife, and for which her estate had previously taken a deduction under sec. 2056(b)(7). D's will directed that any estate tax imposed in relation to any trust included in his taxable estate would be paid out of his residuary estate without apportionment against the legatees, beneficiaries, donees, or transferees.

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D's estate included a QTIP trust that was formed by D's deceased wife, and for which her estate had previously taken a deduction under sec. 2056(b)(7). D's will directed that any estate tax imposed in relation to any trust included in his taxable estate would be paid out of his residuary estate without apportionment against the legatees, beneficiaries, donees, or transferees. Following D's death, his co-executors (Ps) calculated his Federal estate tax utilizing the estate tax apportionment provision prescribed in Ohio Rev. Code Ann. sec. 2113.86(I) (Page 1990); Ps argue here that the…

1Opinion of the Court

ESTATE OF HANS W. VAHLTEICH, DECEASED, JOSHUA LEVINE AND BEVERLY V. DELANEY, CO-EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Vahlteich v. Commissioner

Docket No. 13655-92

United States Tax Court

T.C. Memo 1994-168; 1994 Tax Ct. Memo LEXIS 169; 67 T.C.M. (CCH) 2704;

April 18, 1994, Filed

D's estate included a QTIP trust that was formed by D's deceased wife, and for which her estate had previously taken a deduction under sec. 2056(b)(7). D's will directed that any estate tax imposed in relation to any trust included in his taxable estate would be paid out of his…

2Cases cited18 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Riggs v. Del DragoSupreme Court of the United States · 1942
  3. Espinoza v. CommissionerUnited States Tax Court · 1982
  4. Shiosaki v. CommissionerUnited States Tax Court · 1974
  5. Kroh v. CommissionerUnited States Tax Court · 1992

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