Estate of Childs v. Commissioner
United States Tax Court
1. Held, that under the provisions of her husband's will decedent acquired a life interest and not a fee in his residuary estate, and hence the value of the residuary property is not includable in her estate. 2. At the time of decedent's death 400 shares of H. Childs & Co., Inc. stock were held by her subject to an option at $10.00 per share. The fair market value of the stock at her death was $100 per share.
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1. Held, that under the provisions of her husband's will decedent acquired a life interest and not a fee in his residuary estate, and hence the value of the residuary property is not includable in her estate. 2. At the time of decedent's death 400 shares of H. Childs & Co., Inc. stock were held by her subject to an option at $10.00 per share. The fair market value of the stock at her death was $100 per share. Held, the proper value of such stock for Federal estate tax purposes is $10.00 per share.
1Opinion of the Court
Estate of Anna D. Childs, Deceased, James H. Childs, Harvey Childs, III, Blair Childs and the Union Trust Company of Pittsburgh, Executors, v. Commissioner.
Estate of Childs v. Commissioner
Docket No. 111548.
United States Tax Court
1943 Tax Ct. Memo LEXIS 218; 2 T.C.M. (CCH) 388; T.C.M. (RIA) 45094;
June 30, 1943
1. Held, that under the provisions of her husband's will decedent acquired a life interest and not a fee in his residuary estate, and hence the value of the residuary property is not includable in her estate.
2. At the time of decedent's death 400 shares of H. Childs & Co., Inc. stock were…
2Cases cited9 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Helvering v. SalvageSupreme Court of the United States · 1936
- Estate of TysonSupreme Court of Pennsylvania · 1899
- Bensel v. CommissionerUnited States Board of Tax Appeals · 1937
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