Delone v. Commissioner
United States Tax Court
Petitioner's husband willed to her all of his estate, but directed that she sell his entire 2,544 shares of common stock of a corporation to 3 other major stockholders at $ 100 per share. The estate tax appraisal of the stock was $ 125 per share. Petitioner held 865 shares of such stock independently of the will at a basis of $ 100 per share.
Read the full summary
Petitioner's husband willed to her all of his estate, but directed that she sell his entire 2,544 shares of common stock of a corporation to 3 other major stockholders at $ 100 per share. The estate tax appraisal of the stock was $ 125 per share. Petitioner held 865 shares of such stock independently of the will at a basis of $ 100 per share. Petitioner and the 3 stockholders made an agreement whereby she transferred 693 of her shares to them and her remaining 2,716 shares to the corporation, for a consideration consisting of cash and preferred stock of the corporation. Petitioner also…
1Opinion of the Court
Helen S. Delone, Petitioner, v. Commissioner of Internal Revenue, Respondent
Delone v. Commissioner
Docket No. 6423
United States Tax Court
6 T.C. 1188; 1946 U.S. Tax Ct. LEXIS 179;
May 27, 1946, Promulgated
Decision will be entered unler Rule 50.
Petitioner's husband willed to her all of his estate, but directed that she sell his entire 2,544 shares of common stock of a corporation to 3 other major stockholders at $ 100 per share. The estate tax appraisal of the stock was $ 125 per share. Petitioner held 865 shares of such stock independently of the will at a basis of $ 100 per share. Petitioner…
2Cases cited11 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Helvering v. SalvageSupreme Court of the United States · 1936
- Helvering v. San Joaquin Fruit & Investment Co.Supreme Court of the United States · 1936
- Hoffman v. CommissionerUnited States Tax Court · 1943
- Mack v. CommissionerUnited States Tax Court · 1944
6 more not listed; retrieve them via the Exa API.