Legal Opinion

Owen v. Commissioner

Court of Appeals for the Ninth Circuit

Decided October 26, 1931No. 6323PublishedCited by 6 opinions

1Opinion of the Court

SAWTELLE, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals determining that a deficiency exists in estate taxes due from the estate of petitioner’s intestate, under § 402(a) of the Revenue Act of 1921, 42 Stat. 227, 278, that provides:

*330“That the value, of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated—(a) To the extent of the interest therein of the decedent at the time of his death which after his death is subject to the payment of…

2Cases cited5 opinions

  1. In re the Judicial Settlement of the Account of Proceedings of CohnAppellate Division of the Supreme Court of the State of New York · 1919
  2. In re the Estate of BabcockNew York Surrogate's Court · 1914
  3. Grissom v. SternbergerCourt of Appeals for the Fourth Circuit · 1926
  4. In re the Estate of ValentineNew York Surrogate's Court · 1924
  5. In re the Appraisal of the Estate of BullardAppellate Division of the Supreme Court of the State of New York · 1902

3Cited by6 opinions

  1. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1932
  2. Dulin v. CommissionerCourt of Appeals for the Sixth Circuit · 1934
  3. Byrne v. CommissionerUnited States Tax Court · 1970
  4. Byrne v. CommissionerUnited States Tax Court · 1970
  5. Matthews v. CommissionerUnited States Tax Court · 1989

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