Murphy v. Commissioner
United States Tax Court
Prior to 1942 petitioner and her husband were domiciled in California and held three pieces of real property as community property under the laws of California. On February 9, 1942, petitioner and her husband signed a deed granting the said properties to themselves as joint tenants. On February 15, 1948, petitioner and her husband granted the properties then held as joint tenants to a third person.
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Prior to 1942 petitioner and her husband were domiciled in California and held three pieces of real property as community property under the laws of California. On February 9, 1942, petitioner and her husband signed a deed granting the said properties to themselves as joint tenants. On February 15, 1948, petitioner and her husband granted the properties then held as joint tenants to a third person. On February 16, 1948, the said third person by grant deed granted to petitioner and her husband the properties as tenants in common. Petitioner's husband died testate on December 2, 1948, leaving…
1Opinion of the Court
OPINION
Arundell, Judge:
Respondent determined deficiencies in income tax for the calendar years 1957 and 1958 in the amounts of $7,488.80 and $24,433.01, respectively. Petitioner alleges that she has overpaid her tax for both years.
All of the issues have been settled by stipulation except one. The one remaining issue is whether section 1014(b)(6) of the 1954 Code entitles petitioner to a stepped-up basis for her one-half undivided interest in three parcels of improved real property where, at the time of her husband’s death in 1948, the spouses held these three properties under California law…
2Cases cited10 opinions
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Lang v. CommissionerSupreme Court of the United States · 1933
- Massaglia v. CommissionerUnited States Tax Court · 1959
- Widener v. CommissionerUnited States Board of Tax Appeals · 1927
- Bull v. CommissionerUnited States Board of Tax Appeals · 1927
5 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Murphy v. CommissionerUnited States Tax Court · 1964