Estate of Lang v. Commissioner
United States Tax Court
Decedent made a gift in contemplation of death, incurring a liability for Washington gift taxes, but died before the gift taxes were paid. The gift was includable for Washington inheritance tax purposes and the State gift tax posthumously paid was accepted by Washington as a credit against the inheritance tax.
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Decedent made a gift in contemplation of death, incurring a liability for Washington gift taxes, but died before the gift taxes were paid. The gift was includable for Washington inheritance tax purposes and the State gift tax posthumously paid was accepted by Washington as a credit against the inheritance tax. Held, the Washington gift tax was allowable as a deduction from the Federal gross estate as a claim against the estate under sec. 2053, even though the estate had claimed, and been allowed by respondent to include, the amount of the gift tax in the inheritance taxes creditable under…
1Opinion of the Court
OPINION
Hall, Judge:
Respondent determined the following deficiencies:
Gift Tax — Docket No. 1111-12
Deficiency Penalty— sec. 6651(a)1 ^ 5 £
_1_ $4,560.00 $1,140.00 IO CO Q>
_ 4,575.86 1,143.97 CD CO O
_ 5,770.39 0 OO CD 05
Estate Tax — Docket No. 8176-72
Date of death Deficiency
6/10/68_ $224,746.31
The issues that remain for decision are:(1) Whether decedent’s estate is entitled to a deduction from the Federal gross estate for State gift taxes paid after decedent’s death;(2) Whether decedent made gifts to her son Howard equal to the amount of certain loans to Howard when she permitted the statute of…
2Cases cited22 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- United States v. CorrellSupreme Court of the United States · 1967
- Ingram v. United StatesSupreme Court of the United States · 1959
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
17 more not listed; retrieve them via the Exa API.
3Cited by105 opinions
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Wing v. CommissionerUnited States Tax Court · 1983
- Lawrence Keasler and Keasler Body Company, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1985
- Anselmo v. CommissionerUnited States Tax Court · 1983
- Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
100 more not listed; retrieve them via the Exa API.