Estate of Labombarde v. Commissioner
United States Tax Court
Beatrice M. Labombarde died June 1, 1968. Petitioners, executors of her estate and her only children, had been concerned about decedent's financial situation following the death of their father in 1951. Therefore, in 1952 or 1953, they had agreed among themselves to each convey approximately $ 5,000 per year to or for their mother's benefit so as to permit her to live comfortably.
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Beatrice M. Labombarde died June 1, 1968. Petitioners, executors of her estate and her only children, had been concerned about decedent's financial situation following the death of their father in 1951. Therefore, in 1952 or 1953, they had agreed among themselves to each convey approximately $ 5,000 per year to or for their mother's benefit so as to permit her to live comfortably. In 1966, petitioners, along with the deceased, met with tax counsel to discuss the status of the funds contributed by petitioners. Following counsel's instructions decedent wrote a letter to petitioners which…
1Opinion of the Court
Sterrett, Judge:
Respondent determined a deficiency in the Federal estate tax of the Estate of Beatrice M. Labombarde in the amount of $47,151.02. Due to concessions the issues remaining for adjudication are:(1) Whether money paid to or on behalf of decedent by her three children constitutes an indebtedness deductible under the provisions of section 2058 (a)1 as a claim against her estate.(2) Whether the conveyance by decedent of an interest in Florida realty to her three children 14 months prior to her death was a transfer in contemplation of death.
FINDINGS OF FACT
Some of the facts have been…
2Cases cited30 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Fire Ins. Assn., Ltd. v. WickhamSupreme Court of the United States · 1891
- Griswold v. Heat CorporationSupreme Court of New Hampshire · 1967
- Commonwealth v. Chin KeeMassachusetts Supreme Judicial Court · 1933
- Rude v. CommissionerUnited States Tax Court · 1967
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3Cited by10 opinions
- Estate of Lydia G. Maxwell, Deceased First National Bank of Long Island Victor C. McCuaig Jr., Executors v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993
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- ESTATE OF HUNTINGTON v. COMMISSIONERUnited States Tax Court · 1993
- Estate of Elkins v. United StatesDistrict Court, S.D. Texas · 1978
- Estate of Huntington v. CommissionerUnited States Tax Court · 1993
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