Estate of Cowan v. Commissioner

1965 T.C. Memo. 113, 24 T.C.M. 595, 1965 Tax Ct. Memo LEXIS 218
CourtUnited States Tax Court
DecidedApril 26, 1965
DocketDocket No. 3177-62.
StatusUnpublished

This text of 1965 T.C. Memo. 113 (Estate of Cowan v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Cowan v. Commissioner, 1965 T.C. Memo. 113, 24 T.C.M. 595, 1965 Tax Ct. Memo LEXIS 218 (tax 1965).

Opinion

Estate of Carrie H. Cowan, Deceased, William A. Cowan and Waterloo Savings Bank, Executors v. Commissioner.
Estate of Cowan v. Commissioner
Docket No. 3177-62.
United States Tax Court
T.C. Memo 1965-113; 1965 Tax Ct. Memo LEXIS 218; 24 T.C.M. (CCH) 595; T.C.M. (RIA) 65113;
April 26, 1965

*218 Held, that the decedent, Carrie H. Cowan, forgave an indebtedness of her son prior to her death; and that such forgiveness constituted a gift.

Held, further, that said indebtedness was not forgiven in contemplation of death within the meaning of section 2035(a) of the Internal Revenue Code of 1954.

Craig H. Mosier, National Bldg., Waterloo, Iowa, and David J. Dutton, for the petitioner. Donald W. Wolf, for the respondent.

PIERCE

Memorandum Findings of Fact and Opinion

PIERCE, Judge: Respondent determined*219 a deficiency in estate tax against the Estate of Carrie H. Cowan, in the amount of $13,345.14.

The issues for decision are:

(1) Whether a $70,000 indebtedness to the decedent by her son that arose from his purchase of her interest in a business, was forgiven by the decedent prior to her death, so that if it was not a transfer in contemplation of death it is not includable as an asset of her estate.

(2) If the indebtedness was forgiven by the decedent, whether the same was forgiven in contemplation of death within the meaning of section 2035(a) of the Internal Revenue Code of 1954.

Issue 1 - Findings of Fact

Some of the facts were stipulated. The stipulation of facts and all exhibits identified therein are incorporated herein by reference.

Carrie H. Cowan (hereinafter called "Carrie") died testate on June 14, 1959, a resident of Waterloo, Black Hawk County, Iowa. Her will was admitted to probate; and her son William A. Cowan and the Waterloo Savings Bank were appointed and qualified as the executors of her estate. Both have continued to act in such capacity at all times since their appointment. They filed a Federal estate tax return for Carrie's*220 estate with the district director of internal revenue for the district of Iowa.

Carrie was the widow of William E. Cowan, 1 who had predeceased her on May 9, 1956. Cowan, Sr. at the time of his death was the owner of a wholesale lumber business, founded in 1920, which he operated as a sole proprietorship under the name of Cowan and Cowan Wholesale Lumber Company. Cowan, Jr., who was the only son of Carrie and Cowan, Sr., began working for his father in said business in about 1945; he thereafter became the sales manager; and during the last 18 months of his father's life he was for all practical purposes the responsible executive head of the business.

Cowan, Sr. left a will, under which he gave one-half of his estate outright to his wife, Carrie; and one-half in trust for the benefit of Carrie for life, with the remainder to go to his four children, Cowan, Jr. and three daughters. The trustees of the trust were Carrie and Cowan, Jr. The will contained the following provisions relating to his said proprietorship business:

E. I further will and provide*221 that the wholesale lumber business that I own is to be continued and operated for a period of at least ten years from the date of my death, and I direct that William A. Cowan [i.e., Cowan, Jr.] shall be the manager of said business and shall operate and handle the same for the benefit of my estate, and that he shall be paid for his services as may be agreed upon between the said William A. Cowan, and his Mother, Carrie H. Cowan.

F. In connection with the above handling and managing of the wholesale lumber business, I provide that if at any time during the operation thereof that William A. Cowan is willing and able to purchase said business from his Mother or from the other heirs, that they arrange with him on a sale of the business upon reasonable and fair terms and permit him to pay to my estate the payments as provided by the agreement. I further provide that my son, William A. Cowan shall have the first opportunity and right to purchase the wholesale lumber business, and that in such purchase, he shall be given very liberal terms, both as far as the payments are concerned and as to the time that the business is transferred to him so that he shall have a full and fair opportunity*222 to obtain the ownership.

In late July or early August 1956, Cowan, Jr. entered into an agreement with his mother and also the executors and testamentary trustees under his father's will, whereby he agreed to purchase the wholesale lumber business for a total price of $150,000, of which one-half was to be paid to his mother and the other half was to be paid to the trust. On August 8, 1956, the Iowa probate court entered an order approving such sale; and thereupon Cowan, Jr. executed two promissory notes to cover said purchase price - one of which he delivered to his mother, and the other of which he delivered to the testamentary trustees. Each note was dated August 8, 1956, and was in the amount of $75,000; each was payable at the rate of $7,500 per year, beginning May 1, 1957; and each was non-interest bearing.

Carrie was desirous that her son, Cowan, Jr. have the one-half interest in the business that she had inherited from her husband, without his having to pay her the full $75,000 represented by the promissory note which he had delivered to her personally. She believed that the son's services in the business had contributed materially to its value at the time of her husband's*223 death; and that the son should not have to pay for the fruits of his own work.

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Bluebook (online)
1965 T.C. Memo. 113, 24 T.C.M. 595, 1965 Tax Ct. Memo LEXIS 218, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-cowan-v-commissioner-tax-1965.