Jackman v. Oklahoma Tax Commission

DAVISON, Vice Chief Justice.

This appeal presents a controversy between Grace N. Jackman (Taxpayer) and Oklahoma Tax Commission (The Commission) over the value of the estate of Taxpayer’s deceased husband, George Albert Jackman (Bert Jackman) that is subject to an estate tax under applicable Oklahoma law. Our decision on appeal depends upon whether the necessarily implied finding of the jury that Taxpayer and her deceased husband were equal partners in the ownership and operation of a drug store, can be sustained.

The Taxpayer, as executrix (she was also sole legatee and devisee) of her…