Legal Opinion
Estate of James R. Lowe, Deceased. Crocker National Bank, James R. Lowe, Jr. And Margot H. Lowe, Co-Executors v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 3, 1977No. 76-2105PublishedCited by 9 opinions
1Per curiam
The sole issue on appeal is whether the Tax Court erred in finding that the value of certain property transferred in trust is in-cludable in the gross estate of decedent James Lowe as having been transferred by him “in contemplation of death” within the meaning of the former version of Int.Rev. Code of 1954, § 2035. 1 We affirm.
Since the property was transferred for less than adequate consideration within three years of Lowe’s death, it is presumed to have been transferred in contemplation of death “unless shown to the contrary.” Id. % 2035(b). See First Nat’l Bank v. United States, 488 F.2d…
2Cases cited7 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
- Sullivan's Estate v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1949
- Gillette's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
- Fay Lewis Berman, of the Estate of Joseph Emile Berman v. United StatesCourt of Appeals for the Fifth Circuit · 1973
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Parkside, Inc. And Beaconcrest, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
- Estate of Rosenberg v. CommissionerUnited States Tax Court · 1986
- Estate of Lidbury v. CommissionerUnited States Tax Court · 1985
- Estate of Davis v. CommissionerUnited States Tax Court · 1979
- Estate of Lidbury v. CommissionerUnited States Tax Court · 1985
4 more not listed; retrieve them via the Exa API.