Cranston v. Wells Fargo Bank

The State Controller has appealed from an order upholding the executor’s objections to the valuation placed upon United States treasury bonds by the California inheritance tax appraiser.

Facts: The decedent owned United States treasury bonds with a total par value of $2,200,000. On the date of her death, these bonds were worth in the over-the-counter market $1,872,-185.63.

The federal government, through the Internal Revenue Code or by the terms of the bonds, permits their value to be accelerated to par value by the death of the owner to the extent that the bonds are used to pay federal estate…