Wright v. Commissioner
United States Board of Tax Appeals
1. TRANSFEREES. - Where the petitioners, as heirs at law, each received assets of the decedent's estate having a value in excess of the deficiency in estate tax, each is liable for the tax as a transferee, under section 316(a) of the Revenue Act of 1926, notwithstanding the amount of the deficiency had not been determined nor asserted by the Commissioner until subsequent to distribution of the residue of the estate. 2. PERSONAL LIABILITY OF FORMER ADMINISTRATORS. - Where the…
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1. TRANSFEREES. - Where the petitioners, as heirs at law, each received assets of the decedent's estate having a value in excess of the deficiency in estate tax, each is liable for the tax as a transferee, under section 316(a) of the Revenue Act of 1926, notwithstanding the amount of the deficiency had not been determined nor asserted by the Commissioner until subsequent to distribution of the residue of the estate. 2. PERSONAL LIABILITY OF FORMER ADMINISTRATORS. - Where the administrators distributed all the assets of decedent's estate among the heirs at law without making provision for…
1Opinion of the Court
*545OPINION.
Trammell:
The respondent determined a deficiency in estate tax against the estate of the decedent H. $6,233.92. Two issues are raised respecting the correctness of that determination. The first issue, namely, whether the respondent erred in increasing the value of a reversionary interest in a certain building from $14,577.60 to $21,866.40, is conceded by the petitioners, and it is now agreed that the respondent’s determination on that point is correct.
The second issue on the merits relates to the gift made by the decedent on December 3, 1926, to his son and daughter-in-law of certain…
2Cases cited5 opinions
- Keller v. CommissionerUnited States Board of Tax Appeals · 1930
- Wire Wheel Corp. v. CommissionerUnited States Board of Tax Appeals · 1929
- Evans v. CommissionerUnited States Board of Tax Appeals · 1928
- Graham v. CommissionerUnited States Board of Tax Appeals · 1932
- Simon v. CommissionerUnited States Board of Tax Appeals · 1927
3Cited by15 opinions
- Maher v. CommissionerUnited States Tax Court · 1970
- Kuckenberg v. CommissionerUnited States Tax Court · 1960
- Leigh v. CommissionerUnited States Tax Court · 1979
- Cleveland v. CommissionerUnited States Board of Tax Appeals · 1933
- United States v. RussellDistrict Court, D. Rhode Island · 1959
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