Montedonico v. Commissioner

12 B.T.A. 572, 1928 BTA LEXIS 3511
CourtUnited States Board of Tax Appeals
DecidedJune 13, 1928
DocketDocket No. 13518.
StatusPublished
Cited by1 cases

This text of 12 B.T.A. 572 (Montedonico 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
Montedonico v. Commissioner, 12 B.T.A. 572, 1928 BTA LEXIS 3511 (bta 1928).

Opinion

[574]*574opinion.

Siefkin:

The executors of the estate of Annie Montedonico, in making the estate tax return, included an account of realty which Annie Montedonico had acquired under the will of her husband, J. D. Montedonico, a one-twelfth interest in certain real property located in Memphis, Tenn.

The will of her husband read in part as follows:

I direct that the life insurance which I carry in the Mutual Life Insurance Company and in the Manhattan life Insurance Company, both of New York, shall be divided equally between my wife, Annie Montedonico, and my five [575]*575children. All of my other property, real, personal, or mixed, I give, bequeath and devise unto my said wife, Annie Montedonico, to be free from the control, custody or management of any future husband. In case my wife should sell any of my real estate, I direct that she divide the proceeds of such sale equally between herself and all of my said children.

At the time of his death, J. D. Montedonico owned a one-half undivided interest in certain real estate in Memphis, Tenn., the other one-half interest being owned by his brother, Louis Montedonico.

The value of the real property included in the will was fixed by the respondent at $103,000 and this value is not contested.

Section 402 of the Revenue Act of 1921 provides:

That the value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated—
(a) To the extent of the interest therein of the decedent at the time of his death which after his death is subject to the payment of the charges against his estate and the expenses of its administration and is subject to distribution as part of his estate.

We must determine the interest in the realty which Annie Monte-donico held at. her death, and it becomes necessary to interpret the will, since it has not been judicially construed by the courts of Tennessee. The respondent has held that under the will of her husband Annie Montedonico acquired all of her husband’s interest in the property.

In the depositions in this proceeding evidence was submitted as to statements made by Joseph D. Montedonico before his death to show his intentions as to the disposition of his property under his will.

In 40 Cyc., at pages 1427-1428, it is said:

Since a will is to be construed from tbe written language of tlie instrument itself, as a general rule parol or extrinsic evidence is not admissible to add to, vary or contradict tbe terms of a will, but may be admitted for tbe purpose of counteracting fraud in a devise or bequest. Thus where a testator’s intention is expressed in plain and unambiguous language, parol or extrinsic evidence is inadmissible to show an intention different from that shown in the will.

In Barber v. Pittsburgh, etc. Ry., 166 U. S. 83-109, the court said:

* * * Evidence of extrinsic circumstances, such as the testator’s relation to persons, or the amount and condition of his estate, may be admitted to explain ambiguities of description in the will, but never to control the construction or extent of devises therein contained. As said by this court, speaking by Mr. Justice Grier: “A court may look beyond the face of the will where there is an ambiguity as to the person or property to which it is applicable, but no case can be found where such testimony has been introduced to enlarge or diminish the estate devised.” King v. Ackerman, 2 Black, 408, 418. See also Allen v. Allen, 18 How. 385.

[576]*576In the instant proceeding, we can see no ambiguity in the language used in the will, and we must, therefore, determine from the will itself the interest in the property which Annie Montedonico acquired thereunder.

In Barber v. Pittsburgh, etc. Ry., supra, the court said at page 99:

Where the construction of certain words in deeds or wills of real estate has become a settled rule of property in a state, that construction is to be followed by the Courts of the United States in determining the title to land within the State, whether between the same or between other parties.

We must, therefore, turn our attention to the laws regarding real property as applied in Tennessee.

Section 3672 Shannon’s Code of Tennessee provides:

The term “heirs,” or other words of inheritance, shall not be requisite to create or convey an estate in fee; and every grant or devise of real estate, or any interest therein, shall pass all the estate or interest of the grantor or devisor, unless the intent to pass a less estate or interest shall appear by express terms, or be necessarily implied in the terms of the instrument.

It would appear then that the words “ give, bequeath and devise ” would be sufficient to create an absolute estate in the absence of express terms to the contrary.

Does the statement, “ In case my wife should sell any of my real estate, I direct that she divide the proceeds of such sale equally between herself and all of my said children,” contained in the will, operate to defeat the vesting of a fee simple in Annie Montedonico?

In the case of Williamson v. Tunis, 64 S. W. 10, decided by the Supreme Court of Tennessee the testator devised his realty to his daughter, but upon her death without issue, to her surviving brothers and sisters. The court said in part:

Tbe contention on complainant’s part is that tbe proper construction of sucb limitation is that, in the event there is issue, as in case of Mrs. Green, such issue take a remainder under the will; while for the defendants the contention is that, in the event there is issue, the estate of the first taken, Mrs. Green, became absolute — in other words, the estate was vested in Mrs. Green, subject only to be defeated by her dying without issue.
* * * * * * *
The consequence is that, as to Mrs. Green’s share it is absolute under the terms of the will, except in the one contingency that she die leaving no issue; and, that contingency not having happened, but she having died leaving issue, the estate was absolute, and would, in the absence of any other disposition, have passed to her heirs as such, and her children would have had no interest as devisees, though they might have taken as heirs, * * *.

In Anderson v. Lucas (Tenn.), 204 S. W. 989, the testator devised real estate to trustees for the benefit of his daughter for life and if she should die without issue, the property to be equally divided among other daughters and their heirs. It was held that the daughter took an estate in fee. On page 993 the Court said:

[577]

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Related

Montedonico v. Commissioner
12 B.T.A. 572 (Board of Tax Appeals, 1928)

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Bluebook (online)
12 B.T.A. 572, 1928 BTA LEXIS 3511, Counsel Stack Legal Research, https://law.counselstack.com/opinion/montedonico-v-commissioner-bta-1928.