Estate of Elliott v. Commissioner
United States Tax Court
Decedent purchased U.S. savings bonds (series E) with her own funds. The bonds were registered in coownership form in the name of decedent or her daughter or grandchildren. The bonds were kept in a bank safe-deposit box rented by decedent in her name and to which she had access until her death. About 6 years before she died, decedent gave the keys to the safe-deposit box to her daughter and after that time never entered the box again.
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Decedent purchased U.S. savings bonds (series E) with her own funds. The bonds were registered in coownership form in the name of decedent or her daughter or grandchildren. The bonds were kept in a bank safe-deposit box rented by decedent in her name and to which she had access until her death. About 6 years before she died, decedent gave the keys to the safe-deposit box to her daughter and after that time never entered the box again. Delivery of the keys was recorded in decedent's diary. The bonds remained in the safe-deposit box until the decedent's death. Held: (1) The Treasury regulations…
1Opinion of the Court
Dawson, Judge:
In these consolidated cases the respondent determined a Federal estate tax deficiency of $79,266.31 against the Estate of Mae Elliott, Mrs. J. E. Crabtree, a.k.a. Mary Kathryn Crabtree, executrix, in docket No. 5731-69. In respect of such determination, respondent also asserted, pursuant to section 6901, I.R.C. 1954,2 the following fiduciary and transferee liabilities;
Petitioner Docket No. Amount
Mrs. J. E. Crabtree, sole heir, a.k.a. Mary Kathryn
SÍJ Crabtree, sole heir of Mae Elliott_ 5732-69 $79, 266. 31
Mrs. J. E. Crabtree, a.k.a. Mary Kathryn Crabtree— 5733-69 79, 266. 31
Mrs.…
2Cases cited20 opinions
- Free v. BlandSupreme Court of the United States · 1962
- Conrad v. ConradCalifornia Court of Appeal · 1944
- Harmon v. SchmitzTexas Commission of Appeals · 1931
- Katz v. DriscollCalifornia Court of Appeal · 1948
- Wells v. SansingTexas Supreme Court · 1952
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3Cited by5 opinions
- United States v. ChandlerSupreme Court of the United States · 1973
- Estate of Mae Elliott, Mrs. J. E. Crabtree, A/K/A Mary Kathryn Crabtree v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Estate of Sulovich v. CommissionerUnited States Tax Court · 1976
- Estate of Elliott v. CommissionerUnited States Tax Court · 1971
- Estate of Sulovich v. CommissionerUnited States Tax Court · 1976