Estate of Goldsborough v. Commissioner
United States Tax Court
In 1946 decedent Goldsborough transferred to her two daughters real property worth $ 25,000. In 1949, the daughters sold the real property for $ 32,500 and separately invested their respective shares of the proceeds in stock and securities to which title was taken in the names of the purchaser and decedent Goldsborough.
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In 1946 decedent Goldsborough transferred to her two daughters real property worth $ 25,000. In 1949, the daughters sold the real property for $ 32,500 and separately invested their respective shares of the proceeds in stock and securities to which title was taken in the names of the purchaser and decedent Goldsborough. At Goldsborough's death in 1972, the stock and securities had a value of $ 160,383.19. Held, under sec. 2040, the portion of the value of the stock and securities attributable to the gain realized by the two daughters in 1949 on the sale of the real property (7,500/32,500 of $…
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in the amount of $51,790.20 in the Federal estate taxes of the Estate of Marcia P. Goldsborough. In these consolidated cases, the issues for decision are as follows:(1) To what extent, if any, are the values of certain stocks and securities jointly held by the decedent Marcia P. Goldsborough on the date of her death excludable from the gross estate under section 2040.2(2) Whether transferee liability has been established for the Estate of Harriette G. O’Donoghue3 pursuant to sections 6324(a)(2) and 6901(a) and (h) and, if so, whether…
2Cases cited17 opinions
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- Wilkes-Barre Carriage Co. v. CommissionerUnited States Tax Court · 1963
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3Cited by17 opinions
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- Pert v. CommissionerUnited States Tax Court · 1995
- Hunter v. CommissionerUnited States Tax Court · 1982
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