Estate of Neugass v. Commissioner
United States Tax Court
Decedent's will gave to his surviving spouse and daughter successive life estates in his art collection and the remainder interest therein to a foundation. The will further provided that, within 6 months after the date of his death, his surviving spouse could elect to take absolute ownership of any item in the collection.
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Decedent's will gave to his surviving spouse and daughter successive life estates in his art collection and the remainder interest therein to a foundation. The will further provided that, within 6 months after the date of his death, his surviving spouse could elect to take absolute ownership of any item in the collection. Within the 6-month period, the surviving spouse elected to take absolute ownership of certain items, and the estate included their value in its computation of the marital deduction. Held, the surviving spouse was given a terminable interest in the items of which she took…
1Opinion of the Court
Estate of Ludwig Neugass, Deceased, Herbert Marx, Jacques Coe, Jr., and Chase Manhattan Bank, N.A., Executors, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Neugass v. Commissioner
Docket No. 4734-73
United States Tax Court
65 T.C. 188; 1975 U.S. Tax Ct. LEXIS 45;
October 29, 1975, Filed
Decision will be entered under Rule 155.
Decedent's will gave to his surviving spouse and daughter successive life estates in his art collection and the remainder interest therein to a foundation. The will further provided that, within 6 months after the date of his death, his surviving…
2Cases cited19 opinions
- Jackson v. United StatesSupreme Court of the United States · 1964
- Estate of Edward F. Pipe, Deceased, Nettie M. Pipe v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Pipe v. CommissionerUnited States Tax Court · 1954
- Dorothy Jane Dougherty and Louis F. Baldwin, Executors of the Estate of Allen P. Jackson v. United StatesCourt of Appeals for the Sixth Circuit · 1961
- Elizabeth Joan Allen and Alice Edna Stuhmer, Individually and as Executrices of the Estate of Chester A. Allen, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1966
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