Kanawha Banking & Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Value of corporation stock at date of decedent's death determined. 2. Value of city lots determined. 3. Value of land in West Virginiaheld includable in decedent's estate under section 302(a), Revenue Act of 1924. West Virginia Code, 1923, ch. 86, § 3, which subjects all real estate of decedent to "the decedent's debts and all lawful demands against his estate," construed as subjecting real estate to expenses of administration.
1Opinion of the Court
*381OPINION..
Matthews :
With respect to the shares of stock in the Kanawha City Co., the only issue raised is the value at which they should be included in decedent’s gross estate. With respect to the land owned by decedent in West Virginia, there are two issues: (1) Whether this land could properly be included as part of the estate under West Virginia law, under the doctrine of Crooks v. Harrelson, 282 U.S. 55; and (2) if so, its value on the basic date. The parties stipulated that the 1,000 shares of common stock of the Kanawha Land Co. held by decedent at his death had a value for estate tax…
2Cases cited8 opinions
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- United States v. FieldSupreme Court of the United States · 1921
- Alexander v. ByrdSupreme Court of Virginia · 1889
- Virginia v. West VirginiaSupreme Court of the United States · 1907
- United States Fidelity & Guaranty Co. v. PeopleSupreme Court of Colorado · 1908
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3Cited by2 opinions
- Kanawha Banking & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- McIntosh v. CommissionerUnited States Tax Court · 1967