ESTATE OF LOVELAND v. COMMISSIONER

Docket No. 16924.

13 T.C. 5 (1949)

ESTATE OF HAROLD LOVELAND, HATTIE F. LOVELAND, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 6, 1949.


Attorney(s) appearing for the Case

Edward W. Raye, Esq., for the petitioner.

Leo C. Duersten, Esq., for the respondent.


The Commissioner determined a deficiency in estate tax in the amount of $6,617.66. The only question for decision is whether the interest which the decedent's spouse had in certain jointly held property had been acquired from the decedent for a full and adequate consideration in money or money's worth within the meaning of section 811 (e) (1) of the Internal Revenue Code.

FINDINGS OF FACT.

The decedent died on April 25, 1945, while residing in Massachusetts...

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