Estate of Reeves v. Commissioner
United States Tax Court
Decedent owned 511,160 shares of Realtron stock. The value of the shares was included when valuing the gross estate and was included in determining the value of the residue which qualified for the marital deduction pursuant to sec. 2056, I.R.C. The shares formed part of the decedent's general estate out of which the marital bequest could be satisfied.
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Decedent owned 511,160 shares of Realtron stock. The value of the shares was included when valuing the gross estate and was included in determining the value of the residue which qualified for the marital deduction pursuant to sec. 2056, I.R.C. The shares formed part of the decedent's general estate out of which the marital bequest could be satisfied. The executors of decedent's estate sold the Realtron shares to the Realtron Employees' Stock Ownership Plan, qualifying the estate for a deduction of 50 percent of the proceeds pursuant to sec. 2057, I.R.C. Held: The marital deduction must be…
1Opinion of the Court
Hamblen, Chief Judge:
Respondent determined a deficiency in the Federal estate tax of the Estate of Hazard E. Reeves (petitioner) in the amount of $1,100,700.69. This case is before the Court pursuant to Rule 122 on the parties’ fully stipulated facts. The issue for our decision is whether the marital deduction must be adjusted to reflect the deduction allowed for the sale of employer shares to an employee stock ownership plan (esop) under section 2057.
Unless otherwise noted, all section references are to the Internal Revenue Code in effect at decedent’s date of death, and all Rule references…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Barr v. United StatesSupreme Court of the United States · 1945
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
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3Cited by1 opinion
- Estate of Reeves v. CommissionerUnited States Tax Court · 1993