Estate of Pfohl v. Commissioner
United States Tax Court
U.S. Treasury bonds, otherwise qualified for use at par in payment of Federal estate taxes, were purchased for decedent at a time when she was in a comatose state. The purchase was made pursuant to a power of attorney granted by decedent when she was not in such state. The tender of the bonds in payment of estate taxes by decedent's executor was refused by the Bureau of Public Debt.
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U.S. Treasury bonds, otherwise qualified for use at par in payment of Federal estate taxes, were purchased for decedent at a time when she was in a comatose state. The purchase was made pursuant to a power of attorney granted by decedent when she was not in such state. The tender of the bonds in payment of estate taxes by decedent's executor was refused by the Bureau of Public Debt. Held, since the bonds were eligible for redemption at par in payment of Federal estate taxes under sec. 6312, I.R.C. 1954, they are includable in the gross estate at their par value.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined a deficiency of $358,872.49 in petitioner’s Federal estate tax. Other items having been settled by the parties, the sole issue remaining for decision is whether certain U.S. Treasury bonds of a type redeemable at par value in payment of estate tax liabilities were includable in decedent’s gross estate at their par value rather than their fair market value at the date of death.
All of the facts have been stipulated and are found accordingly. The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference.
Pauline…
2Cases cited27 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- United States v. Little Lake Misere Land Co.Supreme Court of the United States · 1973
- Bank of America National Trust & Savings Ass'n v. ParnellSupreme Court of the United States · 1956
- Finch v. GoldsteinNew York Court of Appeals · 1927
- Ortelere v. Teachers' Retirement BoardNew York Court of Appeals · 1969
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3Cited by13 opinions
- Estate of Papson v. CommissionerUnited States Tax Court · 1980
- United States v. MannyCourt of Appeals for the Second Circuit · 1981
- Campbell v. United StatesUnited States Court of Claims · 1981
- United States v. MannyDistrict Court, S.D. New York · 1978
- Estate of Watson v. CommissionerUnited States Tax Court · 1990
8 more not listed; retrieve them via the Exa API.