Bache Trust v. Commissioner
United States Tax Court
In 1948, the petitioner trusts paid additional estate taxes on the estate of decedent Jules S. Bache pursuant to the respondent's determination that their corpora were gifts in contemplation of death. Their assets consisted of certain shares of stock. After payment of the additional estate taxes, they sold a part of such shares and in computing the gain thereon added to their bases the proportionate amount of additional estate taxes which they had paid.
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In 1948, the petitioner trusts paid additional estate taxes on the estate of decedent Jules S. Bache pursuant to the respondent's determination that their corpora were gifts in contemplation of death. Their assets consisted of certain shares of stock. After payment of the additional estate taxes, they sold a part of such shares and in computing the gain thereon added to their bases the proportionate amount of additional estate taxes which they had paid. Held, the estate taxes paid by petitioner trusts were not payments to protect and preserve their assets within the meaning of section 113 (b)…
1Opinion of the Court
Jules S. Bache Trust for Hazel B. Beckman u/d Dated June 1, 1921, Clifford W. Michel, C. Frank Reavis and William B. Franke, Surviving and Successor Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent. Jules S. Bache Trust for Kathryn B. Miller u/d Dated December 15, 1927, Gilbert Miller, Clifford W. Michel and Paul Felix Warburg, Surviving and Successor Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent
Bache Trust v. Commissioner
Docket Nos. 49908, 50063
United States Tax Court
24 T.C. 960; 1955 U.S. Tax Ct. LEXIS 107;
August 31, 1955, Filed
Decisions will be…
2Cases cited1 opinion
- Bache Trust v. CommissionerUnited States Tax Court · 1955