Estate of Shafer v. Commissioner
United States Tax Court
In 1939, independent parties sold vacation property and executed a deed granting decedent and his wife life interests, with remainder interests to their two sons. The deed states that "one dollar and other valuable considerations" were paid by decedent, his wife, and his two sons. The wife predeceased decedent.
Read the full summary
In 1939, independent parties sold vacation property and executed a deed granting decedent and his wife life interests, with remainder interests to their two sons. The deed states that "one dollar and other valuable considerations" were paid by decedent, his wife, and his two sons. The wife predeceased decedent. In connection with respondent's audit of her estate, the sons, executors of her estate, swore in affidavits that decedent bought the property and was a sole purchaser. The sons also became executors of decedent's estate. In a letter from one of the sons in connection with respondent's…
1Opinion of the Court
Chabot, Judge:
Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $56,738.33. The issue presented is whether under section 20361 the decedent’s gross estate includes a lot, the deed to which conveyed life interests to decedent and his wife and remainder interests to his two sons.2
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and the stipulated exhibits are incorporated herein by this reference.
Petitioner’s coexecutors are Arthur Chase Shafer and Robert Resor Shafer (hereinafter sometimes referred to individually as Chase and…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. HallockSupreme Court of the United States · 1940
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Foster v. Comm'rUnited States Tax Court · 1983
14 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Estate of Arthur Chase Shafer, Deceased, Chase Shafer, Co-Executor, and Resor Shafer, Co-Executor v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- John Michael Wheeler, Independent of the Estate of Elmore K. Melton, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Berger v. CommissionerUnited States Tax Court · 1996
- Steiner v. CommissionerUnited States Tax Court · 1995
8 more not listed; retrieve them via the Exa API.