Estate of Gregg v. Commissioner
United States Tax Court
Decedent held certain realty in a sec. 676 revocable trust. Prior to the grantor's death, the realty was condemned. The trust began replacing the condemned realty. However, the grantor died before completion of the replacement plans. The trust nevertheless continued replacing the condemned realty with other property similar or related in service or use.
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Decedent held certain realty in a sec. 676 revocable trust. Prior to the grantor's death, the realty was condemned. The trust began replacing the condemned realty. However, the grantor died before completion of the replacement plans. The trust nevertheless continued replacing the condemned realty with other property similar or related in service or use. The grantor's surviving spouse and the executor of his estate jointly elected nonrecognition treatment under sec. 1033 for the replacements made both before and after the grantor's death. Held, the grantor is the taxpayer for purposes of sec.…
1Opinion of the Court
Estate of Harry A. Gregg, Hugh Gregg, Executor, and Harriett H. Gregg, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Gregg v. Commissioner
Docket No. 5580-76
United States Tax Court
69 T.C. 468; 1977 U.S. Tax Ct. LEXIS 10;
December 12, 1977, Filed
Decision will be entered under Rule 155.
Decedent held certain realty in a sec. 676 revocable trust. Prior to the grantor's death, the realty was condemned. The trust began replacing the condemned realty. However, the grantor died before completion of the replacement plans. The trust nevertheless continued replacing the condemned…
2Cases cited9 opinions
- Estate of Jayne v. CommissionerUnited States Tax Court · 1974
- De Amodio v. CommissionerUnited States Tax Court · 1960
- Inez De Amodio, in No. 13740, John Amodio (Marquis Deamodio), in No. 13741 v. Commissioner of Internatal RevenueCourt of Appeals for the Third Circuit · 1962
- In Re Goodman's Estate. Goodman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Estate of Morris v. CommissionerUnited States Tax Court · 1971
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