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BLACK v. C.I.R.

No. 84-7491.

765 F.2d 862 (1985)

Richard H. BLACK, deceased, Phyllis M. Black, Personal Representative, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 9, 1985.

Attorney(s) appearing for the Case

Stephen S. Case, Sun City, Ariz., for petitioner-appellant.

Jonathan S. Cohen, Washington, D.C., for respondent-appellee.

Before SNEED, TANG and CANBY, Circuit Judges.

CANBY, Circuit Judge:

Petitioner Phyllis Black, personal representative of the estate of Richard Black, appeals from a judgment of the United States Tax Court finding an estate tax deficiency of $39,666.00. The issue is whether the entire value of assets formerly held in joint tenancy by the decedent and his spouse, less the contribution of the surviving spouse, should be included in the gross estate under I.R.C. § 2040...

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