Farrier v. Commissioner
United States Tax Court
1. Administration of estate held completed when decedent's debts were paid and all other duties pertaining to administration were performed by the executor, except distribution of the assets of the estate to the life beneficiary under decedent's will. 2. Gift by the life beneficiary to her daughter of certain cattle which had been raised by the estate after decedent's death held not to have resulted in taxable gain to the donor.
1Opinion of the Court
OPINION.
LeMire, Judge:
Our principal question here is whether decedent’s estate was closed, or should be treated as closed, for income tax purposes, for the taxable years 1945 to 1948, inclusive, so that the income therefrom is all taxable to the life beneficiary. Respondent contends that the period of administration of the estate must be considered as having ended prior to May 31, 1945. Petitioners contend that the estate was not closed until after the sale of the principal assets by the executor in 1948. The effect of continuing the administration and distributing only a portion of the…
2Cases cited7 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Chick v. CommissionerUnited States Tax Court · 1946
- Armstrong v. CommissionerUnited States Tax Court · 1943
- Pierce Estates, Inc. v. CommissionerUnited States Tax Court · 1944
- Caratan v. CommissionerUnited States Tax Court · 1950
2 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Brown v. United StatesCourt of Appeals for the Fifth Circuit · 1989
- Williams v. CommissionerUnited States Tax Court · 1951
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
- Walter R. Carrington and Ada Raye Carrington v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
33 more not listed; retrieve them via the Exa API.