Estate of Richardson v. Commissioner
United States Tax Court
Estimated interest payable on Federal estate tax and State inheritance tax, and on deficiencies with regard to such taxes, is chargeable to the income of the estate and does not reduce the amount of the marital deduction.
1Opinion of the Court
FINDINGS OF FACT AND OPINION
DRENNEN, Judge:
Respondent determined a deficiency in petitioners’ Federal estate tax in the amount of $136,456. The sole issue1 presented by the parties for decision is whether interest payable by the petitioners on (i) Federal estate taxes, (ii) State inheritance taxes, and (iii) deficiencies with regard to such taxes should reduce the net value of the property interest passing to the surviving spouse which qualifies for the marital deduction allowable to petitioners under Code section 2056(a).2
FINDINGS OF FACT
Walter E. Richardson, Jr. died testate on January 1,…
2Cases cited16 opinions
- Russell v. United StatesSupreme Court of the United States · 1929
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Todd v. CommissionerUnited States Tax Court · 1971
- Estate of Bailly v. CommissionerUnited States Tax Court · 1983
- T. S. Ballance, Administrator De Bonis Non With the Will Annexed of the Estate of Samuel D. Jarvis, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1965
11 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Estate of Hubert v. CommissionerUnited States Tax Court · 1993
- Estate of Street v. CommissionerCourt of Appeals for the Sixth Circuit · 1992
- Estate of Hubert v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 1995
- Estate of Fine v. CommissionerUnited States Tax Court · 1988
- Estate of Ruby Miller Whittle, Deceased, Citizens National Bank of Decatur, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1993
18 more not listed; retrieve them via the Exa API.