Matthews v. Commissioner
United States Tax Court
1. Decedent and a business associate, who were both officers and stockholders of X corporation, entered into a reciprocal agreement under which the survivor was to have the option to purchase for a limited time after the death of the other and for a stipulated price all of the shares of X corporation which the other should own at the time of his death. Both parties were free to dispose of any or all of such shares during their lifetime.
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1. Decedent and a business associate, who were both officers and stockholders of X corporation, entered into a reciprocal agreement under which the survivor was to have the option to purchase for a limited time after the death of the other and for a stipulated price all of the shares of X corporation which the other should own at the time of his death. Both parties were free to dispose of any or all of such shares during their lifetime. Held, that the shares of X stock which decedent owned at the time of his death should be included in his gross estate at their fair market value at the time…
1Opinion of the Court
Smith, Judge:
This proceeding involves an estate tax deficiency of $21,009.01, all of which, is in controversy. The questions for our determination are:(1) The valuation, for estate tax purposes, of certain corporate shares which decedent owned at the time of his death but which under the terms of an existing agreement a business associate had an option to purchase within a stated period at a stipulated price. ‘(2) Whether the proceeds of the policies of insurance on decedent’s life which were paid to a creditor bank to whom decedent had assigned the policies as collateral security on his…
2Cases cited33 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Klein v. United StatesSupreme Court of the United States · 1931
- Edwards v. SlocumSupreme Court of the United States · 1924
28 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Bankers Trust Company, as of the Will of Harriet Delta Ellis, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1960
- Bintliff v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Baltimore National Bank v. United StatesDistrict Court, D. Maryland · 1955
- Bintliff v. United StatesCourt of Appeals for the Fifth Circuit · 1972
13 more not listed; retrieve them via the Exa API.