(DOWNLOAD) "Estate of Arthur Chase Shafer v. Commissioner of Internal Revenue" by United States Court Of Appeals For The Sixth Circuit # Book PDF Kindle ePub Free
eBook details
- Title: Estate of Arthur Chase Shafer v. Commissioner of Internal Revenue
- Author : United States Court Of Appeals For The Sixth Circuit
- Release Date : January 11, 1984
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 76 KB
Description
CELEBREZZE, Senior Circuit Judge. This appeal concerns the includability of the value of a parcel of property in the gross estate of Arthur C. Shafer (Arthur). The Commission of the Internal Revenue Service, contending that pursuant to I.R.C. § 2036(a)(1982) the value of the property should have been included in Arthurs gross estate, filed a notice of deficiency against the estate. The decedents two sons, Arthur Chase Shafer (Chase) and Robert Resor Shafer (Resor), in their capacity as co-executors of their fathers estate, petitioned the United States Tax Court for a redetermination of the deficiency. The co-executors argued that the property was not includable because Arthur had not paid for the lot and because no "transfer" within the meaning of Section 2036(a) had occurred. The Tax Court, relying upon affidavits executed by Chase and Resor and a letter from Chase to an Internal Revenue agent, concluded that Arthur had paid for the property and that there had been a "transfer" for federal estate tax purposes; consequently, the Tax Court upheld the Commissioners notice of deficiency. Chase and Resor, asserting that the court admitted improperly into evidence the two affidavits and letter and erred in defining "transfer" for purposes of Section 2036(a), appeal from the Tax Courts determination. We conclude that the challenged documents were admitted properly into evidence and that the Tax Court interpreted correctly Section 2036(a). Accordingly, we affirm.
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