Estate of Walburga Hedrick, Deceased, AKA Walburga Oesterreich, Ray Bert Hedrick v. Commissioner of Internal Revenue

Ninth Circuit

Estate of Walburga Hedrick, Deceased, AKA Walburga Oesterreich, Ray Bert Hedrick v. Commissioner of Internal Revenue

457 F.2d 501

CourtCourt of Appeals for the Ninth Circuit

DecidedJune 28, 1972

Docket26292

StatusPublished

This text of 457 F.2d 501 (Estate of Walburga Hedrick, Deceased, AKA Walburga Oesterreich, Ray Bert Hedrick v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Estate of Walburga Hedrick, Deceased, AKA Walburga Oesterreich, Ray Bert Hedrick v. Commissioner of Internal Revenue, 457 F.2d 501 (9th Cir. 1972).

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Opinion

PER CURIAM:

The decision of the Tax Court, pursuant to our Estate of Hedrick v. Commissioner of Internal Revenue, 406 F.2d 587 (9th Cir., 1969), is affirmed.

On remand, the Tax Court, in reconstructing the transaction, adopted as to the Hedrick Estate a rate of 7%. This resulted in establishing an original sale value, as reconstructed of an amount about twice the actual cash value of the property at the time of sale.

We find the decision complies with our mandate. The present objections of the Hedrick Estate are primarily directed at our prior opinion, which has become the law of the eases. 1

1

. Earlier decisions concerned with the same transaction are Oesterreich v. Commissioner of Internal Revenue, 226 F.2d 798 (9th Cir. 1955), Commissioner of Internal Revenue v. Wilshire Holding Corp., 288 F.2d 799 (9th Cir. 1961), and Estate of Hedrick v. Commissioner of Internal Revenue, 406 F.2d 587 (9th Cir. 1969).

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