Estate of Friedman v. Comm'r
United States Tax Court
The decedent, within 3 years of her death, transferred certain properties to her stepchildren in compromise of a dispute between them concerning title to those properties. Although the claim which the stepchildren had was an unliquidated one, release from such a claim has a recognizable value in money or money's worth.
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The decedent, within 3 years of her death, transferred certain properties to her stepchildren in compromise of a dispute between them concerning title to those properties. Although the claim which the stepchildren had was an unliquidated one, release from such a claim has a recognizable value in money or money's worth. Commissioner v. Mesta, 123 F. 2d 986 (C.A. 3, 1941). It appearing that the transaction was otherwise at arm's length, held, the transfer of the properties was made for a full and adequate consideration in money or money's worth. Catherine S. Beveridge, 10 T.C. 915 (1948),…
1Opinion of the Court
Dawson, Judge:
Respondent determined the following deficiencies in, and additions to, the gift and estate taxes of petitioner:
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Pursuant to joint motion of the parties, both cases were consolidated for trial. Other issues having been settled by agreement, the sole remaining issue is whether the transfer of certain real property by Gertrude Friedman within 8 years of her death was made for an adequate and full consideration in money or money’s worth.
findings of fact
Most of the facts have been stipulated by the parties. Their stipulation, together with attached exhibits, is…
2Cases cited9 opinions
- Harris v. CommissionerSupreme Court of the United States · 1950
- Bailey v. SmithSupreme Court of Florida · 1925
- Commissioner of Internal Revenue v. MestaCourt of Appeals for the Third Circuit · 1941
- Goetchius v. CommissionerUnited States Tax Court · 1951
- Young v. BiehlIndiana Supreme Court · 1906
4 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- United States v. Howard Past, of the Estate of Edna C. Rosedale Ogg, DeceasedCourt of Appeals for the Ninth Circuit · 1965
- Estate of Cyril I. Magnin, Deceased Donald Isaac Magnin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- John Michael Wheeler, Independent of the Estate of Elmore K. Melton, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Old Colony Trust Co. v. Commissioner of Corporations & TaxationMassachusetts Supreme Judicial Court · 1964
- Estate of McLendon v. CommissionerUnited States Tax Court · 1993
15 more not listed; retrieve them via the Exa API.