Union Guardian Trust Co. v. Commissioner
United States Board of Tax Appeals
Under section 303(a)(1), Revenue Act of 1926, authorizing the deduction from the gross estate of such amounts for claims against the estate, to the extent that such claims were incurred or contracted bona fide for an adequate and full consideration in money or money's worth, as are allowed by the laws of the jurisdiction under which the estate is being administered, the deduction allowable for debts of a decedent includes all debts which are by the laws of the jurisdiction…
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Under section 303(a)(1), Revenue Act of 1926, authorizing the deduction from the gross estate of such amounts for claims against the estate, to the extent that such claims were incurred or contracted bona fide for an adequate and full consideration in money or money's worth, as are allowed by the laws of the jurisdiction under which the estate is being administered, the deduction allowable for debts of a decedent includes all debts which are by the laws of the jurisdiction recognized in the settlement of the estate as actual and valid claims, and, where such claims exceed the amount of the…
1Opinion of the Court
OPINION.
Murdook:
The Commissioner determined a deficiency of $30,-434.13 in estate tax. The issue is whether or not the Commissioner erred in disallowing $308,860.39 of a deduction claimed on account of debts of the decedent. The petitioner also raises an alternative issue as to $156,740.78 of the above amount. The facts have been stipulated.
The decedent, Carl H. L. Fliiiterrnarm, died on January 18, 1931, a resident of Oakland County, Michigan. His gross estate consisted of the following:
1. Assets as inventoried in the Probate Court of Oakland County, Michigan, at values determined by the…
2Cited by9 opinions
- Helvering v. Northwestern Nat. Bank & Trust Co. of MinneapolisCourt of Appeals for the Eighth Circuit · 1937
- Commissioner of Internal Revenue v. WindrowCourt of Appeals for the Fifth Circuit · 1937
- Commissioner of Internal Revenue v. LyneCourt of Appeals for the First Circuit · 1937
- Commissioner of Internal Revenue v. WindrowCourt of Appeals for the Fifth Circuit · 1937
- Hallock v. CommissionerUnited States Board of Tax Appeals · 1936
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