Legal Opinion

Provident Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided January 8, 1927No. Docket No. 4976Published

1. The common-law doctrine of estates by the entirety obtains in Pennsylvania, and as, under the common law, there was no transfer of such estate to the surviving spouse upon the death of the decedent, the value of such estate may not be included in the gross estate of the decedent. 2. Ground rents being real estate, and title thereto being held by decedent and his wife as tenants by the entirety, the value of such rents may not be included in the gross estate.

1Opinion of the Court

APPEAL OF PROVIDENT TRUST CO. OF PHILADELPHIA AND CHARLES SINKLER, ADMINISTRATORS, ESTATE OF JAMES K. YOUNG.

Provident Trust Co. v. Commissioner

Docket No. 4976.

United States Board of Tax Appeals

5 B.T.A. 1004; 1927 BTA LEXIS 3693;

January 8, 1927, Promulgated

1. The common-law doctrine of estates by the entirety obtains in Pennsylvania, and as, under the common law, there was no transfer of such estate to the surviving spouse upon the death of the decedent, the value of such estate may not be included in the gross estate of the decedent.

2. Ground rents being real estate, and title thereto being…

2Cases cited1 opinion

  1. Provident Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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