Estate of Rowan v. Commissioner
United States Tax Court
The petitioner obtained a State trial court decree, which adjudicated the decedent's interests in certain property. Held: 1. The decree does not bind this Court for Federal estate tax purposes, since the respondent was not a party to the State court proceeding. 2. The petitioner has failed to sustain the burden of proving the respondent's determinations incorrect with respect to the interests in property includable in the estate and the values thereof. 3. The estate must…
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The petitioner obtained a State trial court decree, which adjudicated the decedent's interests in certain property. Held: 1. The decree does not bind this Court for Federal estate tax purposes, since the respondent was not a party to the State court proceeding. 2. The petitioner has failed to sustain the burden of proving the respondent's determinations incorrect with respect to the interests in property includable in the estate and the values thereof. 3. The estate must include the decedent's right to be paid for certain produce sold and delivered prior to her death, even though the executor…
1Opinion of the Court
Estate of Mary V. Rowan, Reid M. Rowan, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Rowan v. Commissioner
Docket No. 1996-66
United States Tax Court
54 T.C. 633; 1970 U.S. Tax Ct. LEXIS 182;
March 25, 1970, Filed
Decision will be entered under Rule 50.
The petitioner obtained a State trial court decree, which adjudicated the decedent's interests in certain property. Held:
1. The decree does not bind this Court for Federal estate tax purposes, since the respondent was not a party to the State court proceeding.
2. The petitioner has failed to sustain the burden of…
2Cases cited14 opinions
- Erie Railroad v. TompkinsSupreme Court of the United States · 1938
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Freuler v. HelveringSupreme Court of the United States · 1934
- Florence M. Barnes, and Barnes Theatre Ticket Service, Inc., an Illinois Corporation v. The Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
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