Laughinghouse v. Comm'r
United States Tax Court
In 1975, petitioner Margarette S. Laughinghouse acquired real estate from her parents in exchange for a cash payment and two series of promissory notes, one series payable to her father and the other to her mother. The notes and a bank cash loan were secured by mortgages on the land. In February 1976, prior to the due date on any promissory notes to her father, he died, bequeathing the notes due him to Margarette. She was also named and appointed executrix of his will.
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In 1975, petitioner Margarette S. Laughinghouse acquired real estate from her parents in exchange for a cash payment and two series of promissory notes, one series payable to her father and the other to her mother. The notes and a bank cash loan were secured by mortgages on the land. In February 1976, prior to the due date on any promissory notes to her father, he died, bequeathing the notes due him to Margarette. She was also named and appointed executrix of his will. In December 1976, Margarette transferred the real estate, subject to the mortgages, to a newly formed partnership. The notes…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined deficiencies in petitioners’ gift tax liabilities as follows:
Docket Quarter ended
No. Petitioner Dec. 31— Amount
6975-80 Fernie C. Laughinghouse . 1976 $80,825.80
1977 12,194.52
6976-80 Margarette S. Laughinghouse . 1976 86,920.17
1977 12,956.31
After concessions, the sole issue for decision is the value of partnership interests transferred by petitioner Margarette S. Laughinghouse in the quarter ended December 31, 1976. That issue depends on whether the value of real estate that she transferred to a partnership, subject to outstanding mortgages,…
2Cases cited18 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
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- Stonecrest Corp. v. CommissionerUnited States Tax Court · 1955
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