Legal Opinion

Estate of Davis v. Commissioner

United States Tax Court

Decided September 22, 1982No. Docket No. 6603-81Published

Petitioner Janet H. Davis was a cousin of Howard R. Hughes, Jr. After Mr. Hughes' death, petitioner was adjudged a legal heir of Mr. Hughes by a Texas Probate Court, but numerous questions remained as to whether and to what extent, if any, she would share in his estate. These questions included the State in which Mr. Hughes was domiciled, the applicable law on descent and distribution on intestacy, and the validity of numerous alleged wills offered for probate.

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Petitioner Janet H. Davis was a cousin of Howard R. Hughes, Jr. After Mr. Hughes' death, petitioner was adjudged a legal heir of Mr. Hughes by a Texas Probate Court, but numerous questions remained as to whether and to what extent, if any, she would share in his estate. These questions included the State in which Mr. Hughes was domiciled, the applicable law on descent and distribution on intestacy, and the validity of numerous alleged wills offered for probate. Held, legal fees paid by petitioner to establish, prosecute, or defend her right to a share of Mr. Hughes' estate and for advice on…

1Opinion of the Court

Estate of Platt W. Davis, Deceased, Janet H. Davis, Executrix, and Janet H. Davis, Surviving Spouse, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Davis v. Commissioner

Docket No. 6603-81

United States Tax Court

79 T.C. 503; 1982 U.S. Tax Ct. LEXIS 38; 79 T.C. No. 32;

September 22, 1982, Filed

Decision will be entered for the respondent.

Petitioner Janet H. Davis was a cousin of Howard R. Hughes, Jr. After Mr. Hughes' death, petitioner was adjudged a legal heir of Mr. Hughes by a Texas Probate Court, but numerous questions remained as to whether and to what extent, if any,…

2Cases cited20 opinions

  1. United States v. GilmoreSupreme Court of the United States · 1963
  2. Woodward v. CommissionerSupreme Court of the United States · 1970
  3. United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
  4. Boagni v. CommissionerUnited States Tax Court · 1973
  5. Anchor Coupling Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1970

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