Estate of Babbitt v. Commissioner
United States Tax Court
Decedent executed an instrument on Sept. 11, 1980, purporting to convey to each of her 16 children and grandchildren a $ 3,000 interest in her residence.
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Decedent executed an instrument on Sept. 11, 1980, purporting to convey to each of her 16 children and grandchildren a $ 3,000 interest in her residence. Decedent died on Dec. 15, 1980. Held, assuming the Sept. 11, 1980, instrument conveyed valid interests in real property under Texas law, decedent transferred future rather than present interests, which did not qualify for the "annual exclusion" from the gift tax under sec. 2503(b), I.R.C. 1954, and were includable in her gross estate under sec. 2035(a), I.R.C. 1954, as transfers made within 3 years of decedent's death. Held, further, the…
1Opinion of the Court
Estate of Nona H. Babbitt, Deceased, Phyllis B. Anderson and Alvin E. Babbitt, Independent Executors, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Babbitt v. Commissioner
Docket No. 36998-84
United States Tax Court
87 T.C. 1270; 1986 U.S. Tax Ct. LEXIS 14; 87 T.C. No. 73;
December 4, 1986, Filed
Decision will be entered under Rule 155.
Decedent executed an instrument on Sept. 11, 1980, purporting to convey to each of her 16 children and grandchildren a $ 3,000 interest in her residence. Decedent died on Dec. 15, 1980. Held, assuming the Sept. 11, 1980, instrument conveyed…
2Cases cited18 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Tennant v. DunnTexas Supreme Court · 1937
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