Hadden v. Commissioner

10 B.T.A. 741, 1928 BTA LEXIS 4042
CourtUnited States Board of Tax Appeals
DecidedFebruary 14, 1928
DocketDocket No. 9421.
StatusPublished
Cited by3 cases

This text of 10 B.T.A. 741 (Hadden v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hadden v. Commissioner, 10 B.T.A. 741, 1928 BTA LEXIS 4042 (bta 1928).

Opinion

[742]*742OPINION.

Tans sell :

The errors made, in the computation of estate tax, as to the correct amount of executors’ fees to be deducted from the gross estate and as to the value of an additional property to be included in the gross estate, should be corrected in accordance with the facts stipulated by counsel and set forth in the findings of fact.

We have presented for determination the question of whether the respondent has adopted a correct and lawful method for computing the value of that portion of decedent’s residuary estate bequeathed to charity and deductible from the gross estate in determining the [743]*743net taxable estate. The bequests in question are admittedly charitable deductions within the meaning of section 403(a) (3) of the Act of 1921, and the sole issue is whether the amount of the charitable bequests to be deducted from the gross estate should be diminished by State inheritance or transfer taxes.

The respondent’s theory is that the residue of the estate is only what is left after the payment of paramount claims and charges against the estate, including State inheritance or transfer taxes, and that the residuum must be so determined in order to measure the value of the charitable bequests to be deducted, or in other words, that estate taxes are a charge against the estate and that the amount of the deduction to be allowed is the amount to be received by the charitable beneficiaries. The respondent’s theory is not well founded. In the case of New York Trust Co. v. Eisner, 256 U. S. 345, 350, where the executors of the estate brought suit to recover the estate tax paid under the Revenue Act of 1916, on the ground that the Commissioner erroneously disallowed a deduction of State inheritance and succession taxes as charges within the meaning of section 203, the Supreme Court said and so held:

“ Charges against the estate,” as pointed out by the Court below are only charges that affect the estate as a whole, and therefore do not include taxes on the right of individual beneficiaries. This reasoning excludes not only the New York succession tax but those paid to other States, which can stand no better than that paid in New York.

Furthermore, the Federal estate tax here in question is not upon what the beneficiaries may receive, but is by the very provisions of the Act under which it is levied, a tax upon the transfer of the net estate of the decedent.

The respondent cites the case of Young Men's Christian Association v. Davis, 264 U. S. 247, in which case the executor deducted from the gross estate, debts, losses and charges, specific bequests and devises to determine the value of the residuary estate, which was given entirely to charity. He then deducted from the gross estate the residue so determined, together with $50,000 exemption, debts, losses, and charges, to determine the value of the net taxable estate, and paid a tax of $31,000. The question involved was, the effect the payment of the tax would have in the distribution of the estate among the legatees and beneficiaries under the will and whether the tax should be taken out of the residuary estate. The court held that the tax must be paid out of the residuary estate in the absence of any different provision in the will. Clearly this case and other similar cases cited by respondent are not in point with the issue in the case at bar.

[744]*744The taxes in question have been levied under the Revenue Act of 1921, section 401, which imposes upon “ the transfer of the net estate of every decedent dying after the passage of this Act,” a tax equal to specified percentages of the value of the net estate determined as provided in section 403 which provides:

Sec. 403. That for the purpose of the tax the value of the net estate shall be determined—
(a) In the case of a resident, by deducting from the value of the gross estate—
(1) Such amounts for funeral expenses, administration expenses, claims against the estate, unpaid mortgages upon, or any indebtedness in respect to, property (except, in the case of a resident decedent, where such property is not situated in the United States), losses incurred during the settlement of the estate arising from fires, storms, shipwreck, or other casualty, or from theft, when such losses are not compensated for by insurance or otherwise, and such amounts reasonably required and actually expended for the support during the settlement of the estate of those dependent upon the decedent, as are allowed by the laws of the jurisdiction, whether within or without the United States, under which the estate is being administered, but not including any income taxes upon income received after the death of the decedent, or any estate, succession, legacy, or inheritance taxes [Italics ours];
(2) An amount equal to the value of any property forming a part of the gross estate situated in the United States of any person who died within five years prior to the death of the decedent * * * Provided, * * * estate tax * * * was paid by or on behalf of the estate of such prior decedent, * * *
(3) The amount of all bequests, legacies, devices, or transfers, except bona fide sales for a fair consideration in money or money’s worth, in contemplation of or intended to take effect in possession or enjoyment at or after the decedent’s death, to or for the use of the United States, any State, Territory, any political subdivision thereof, or the District of Columbia, for exclusively public purposes, or to or for the use of any corporation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, including the encouragement of art and the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private stockholder or individual, nor to a trustee or trustees exclusively for such religious, charitable, scientific, literary, or educational purposes. This deduction shall be made in case of the estates of all decedents who have died since December 31, 1917; and
(4) An exemption of $60,000; * * *

The above quoted section of the Act is clear and unequivocal in providing that in determining the value of the net taxable estate there shall be deducted certain specific charges against the estate, but prohibits the deduction of “any estate, succession, legacy, or inheritance taxes.” It is clear that for the purposes of the Federal estate tax Congress intended that State inheritance or transfer taxes should not be taken into consideration. In Howard K. Walter, et al., Executors, 2 B. T. A. 453, the Board used the following language:

[745]*745The taxes of both the State and ¡Federal Government depend upon the respective laws of each, and are not affected by the laws of the other. The power of Congress in levying taxes is not necessarily or naturally inconsistent with that of the States. Each may lay a tax on the same property without interfering with the action of the other.

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Related

Continental Illinois Nat'l Bank & Trust Co. v. Commissioner
38 B.T.A. 220 (Board of Tax Appeals, 1938)
Guaranty Trust Co. v. Commissioner
25 B.T.A. 507 (Board of Tax Appeals, 1932)
Hadden v. Commissioner
10 B.T.A. 741 (Board of Tax Appeals, 1928)

Cite This Page — Counsel Stack

Bluebook (online)
10 B.T.A. 741, 1928 BTA LEXIS 4042, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hadden-v-commissioner-bta-1928.