Lande v. Commissioner

21 T.C. 977, 1954 U.S. Tax Ct. LEXIS 264
CourtUnited States Tax Court
DecidedMarch 22, 1954
DocketDocket No. 33532
StatusPublished
Cited by5 cases

This text of 21 T.C. 977 (Lande 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
Lande v. Commissioner, 21 T.C. 977, 1954 U.S. Tax Ct. LEXIS 264 (tax 1954).

Opinion

OPINION.

BRUCE, Judge:

The ultimate issue to be determined in this proceeding is whether respondent erred in disallowing in part claimed deductions on account of funeral and administration expenses and debts, and certain charitable deductions.

The decedent, William Lande, was a trustee, and after the death of his mother, beneficiary of the income of a trust fund established by his mother, with the power, by will, to dispose of the principal of such fund remaining at the time of his death after payment of certain specified items. That he exercised the power of appointment in his will is not disputed. However, since his separate estate, exclusive of the trust property, was not sufficient to pay all of his funeral and administration expenses and debts or any part of the charitable bequests made by him in his will, there is disagreement as to whether the appointive property was applicable to these items. Kespondent takes the position that the assets subject to the power of appointment were not a part of decedent’s estate subject to claims and accordingly, as there were not sufficient assets in decedent’s separate estate to make payments thereof, deductions for certain expenses and charitable bequests were properly disallowed. Petitioners’ position is that, decedent having exercised the power of appointment as to all the property embraced in the trust fund, the debts, expenses, and bequests were payable out of the appointive property and the claimed deductions therefore should be allowed. Petitioners appear to rely principally upon the decree of the Supreme Court for Chemung County, New York, settling the account of the surviving trustee, stating that “the principal passed under the trust agreement to William M. Lande, deceased,” and directing the surviving trustee of the trust to turn the corpus of the trust over to the executors of decedent’s estate “to be administered by them as part of the estate of said William M. Lande, deceased,” and upon the decree of the surrogate court settling the intermediate account of the executors and fixing their commissions, as correctly reflecting the law of New York and binding upon the Commissioner.

It appears from the recitals in the decrees that they were both consent decrees and there is nothing contained therein, or otherwise shown, to indicate that the facts upon which deductibility herein depends were called to the attention of, or passed upon by, the courts which rendered said decrees. Moreover, as hereinafter shown, they do not correctly reflect the law of the State. Accordingly, in determining the deductibility of the items claimed herein for Federal estate tax purposes, this Court is not bound by the decrees mentioned. See Regs. 105, sec. 81.30. Cf. Estate of William A. Carey, 9 T. C. 1047; T. F. Cross, Executor, 5 B. T. A. 621; Tatem Wofford, 5 T. C. 1152, 1161-2.

The parties have made little distinction in their arguments on briefs with respect to the deductions claimed on account of funeral and administration expenses and debts and those claimed on account of charitable bequests. We think they require separate treatment. The one involves the application of section 812 (b) of the Internal Revenue Code; the other the application of section 812 (d).

Respondent explained his adjustments with respect to funeral and administration expenses and debts of decedent as follows:

The above items have been disallowed, in the amount that they exceed the value of property subject to claims [$12,082.43] in accordance with Sec. 812 (5) [sic] of the Internal Revenue Code. It is held that the corpus of the Bertha Lande Trust, in connection with which the decedent validly exercised a power of appointment in his last Will and Testament, does not constitute property subject to claims against his estate. It is further held that the deductions claimed for executors’ commissions and attorney’s fees were excessive under local laws and the Internal Revenue Code to, at least, the extent of $4,457.08.

With respect to funeral and administration expenses and debts of decedent, the question is thus presented: Whether the assets in the trust corpus- of the Bertha Lande trust, over which decedent had and exercised a general testamentary power of appointment, may be treated as “property subject to claims” in determining the allowable deductions under section 812 (b) of the Internal Revenue Code,2 and if so, whether deductions claimed for executors’ commissions and attorney’s fees were excessive under local laws and the Internal Revenue Code to, at least, the extent of $4,457.08.

The debts of decedent at the time of his death totaled $8,868.70, his funeral and administration expenses, $7,670.81. The grand total of these items was $16,539.51. Assets in decedent’s own name at his death, including stocks and bonds, mortgages, notes, cash, jointly owned property, totaled, after adjustments in the notice of deficiency which are not in issue here, $12,032.43. In addition thereto, there was includible in decedent’s gross estate for Federal estate tax purposes the trust corpus, subject to a general testamentary power of appointment, of the value of $101,743.39, after uncontested adjustments to reflect the optional valuation of the various items contained therein less termination expenses and charitable contributions set forth in the trust indenture. Sec. 811 (f), I. E. C.3 Of the total deductions of $16,539.51 claimed by the executors of decedent’s estate, respondent allowed only $12,032.43, representing the value of the assets includible in the decedent’s estate held in his own name, and disallowed the remaining deductions in the amount of $4,457.08.

Petitioners concede, on brief, that without the appointive property the estate of William M. Lande was insolvent.

Under section 812 (b), funeral and administration expenses and debts are deductible for estate tax purposes in such amounts “as are allowed by the laws of the jurisdiction” under which the estate is being administered. In allowing deductions to the extent of $12,032.43, respondent has recognized the deductibility of some part of such items herein. Section 812 (b) further provides, however:

There shall be disallowed the amount by which the deductions specified in paragraphs (1), (2), (3), and (4) exceed the value at the time of the decedent’s death, of property subject to claims. * * * For the purposes of this section the term “property subject to claims” means property includible in the gross estate of the decedent which, or the avails of which, would under the applicable law, bear the burden of the payment of such deductions in the final adjustment and settlement of the estate; * * * [Emphasis supplied.] 4

The trust corpus subject to decedent’s general power of appointment, which he exercised, was clearly “includible in the gross estate of the decedent” for Federal tax purposes. Sec. 811 (f), I. E. C. Under New York probate law, however, such assets, subject to a power as defined in the local statute, do not constitute assets of the decedent’s estate for local probate purposes. In re Beaumont's Estate, 263 N. Y. S. 426 (1933); In re Terwilligar's Estate, 254 N. Y. S. 498 (1931); Farmers' Loan & Trust Co., v. Mortimer, 219 N. Y. 290, 114 N. E. 389 (1916); Cutting v. Cutting, 86 N. Y. 522 (1881).

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Related

Estate of Sorenson v. Commissioner
72 T.C. 1180 (U.S. Tax Court, 1979)
Weber v. Commissioner
29 T.C. 1170 (U.S. Tax Court, 1958)
Lande v. Commissioner
21 T.C. 977 (U.S. Tax Court, 1954)

Cite This Page — Counsel Stack

Bluebook (online)
21 T.C. 977, 1954 U.S. Tax Ct. LEXIS 264, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lande-v-commissioner-tax-1954.