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Commissioner Vs. Estate of Hubert
Cites for this judgment
- US Supreme Court
- Mar 18, 1997
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Commissioner v. EstateSearch
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Of Hubert - 520 U.S. 93 (1997) October Term, 1996 Syllabus Commissioner of Internal Revenue V. EstateSearch
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the controlling valuation date) of the income expected to be used to pay administration expenses. Cf. Ithaca Trust Co. v. UnitedSearch
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b), as interpreted in United States v. StapfSearch
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T. C. 314 (1993). The court noted it had resolved the same issue against the Commissioner in Estate of Street v. CommissionerSearch
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the Sixth Circuit's decision in Street and with the Court of Appeals for the Federal Circuit's decision in Burke v. UnitedSearch
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further supported by Justice Holmes' explanation of valuation theory in his opinion for the Court in Ithaca Trust Co. v. UnitedSearch
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We interpreted this language in United States v. StapfSearch
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estate tax valuation theory that, in the plurality's view, dovetails nicely with our decision in Ithaca Trust Co. v. UnitedSearch
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or ruling because the entity promulgating it did not really want to have to adopt it. See Connecticut Nat. Bank v. GermainSearch
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West Virginia Univ. Hospitals, Inc. v. CaseySearch
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Commissioner's expressed preference for the second one is worthy of deference. National Muffler Dealers Assn., Inc. v. UnitedSearch
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requires that the marital deduction be reduced, see, e. g., Brief for Government Appellee in Ballantine v. TomlinsonSearch
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Brief for Government Appellee in Alston v. UnitedSearch
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National Muffler Dealers Assn., Inc. v. UnitedSearch
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States, 440 U. S. 472 , 477 (1979), quoting United States v. MooreSearch
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National Muffler Dealers Assn., Inc., supra, at 476, quoting United States v. CartwrightSearch
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U. S. 546 , 550 (1973), in turn quoting United States v. CorrellSearch
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U. S. 299 , 307 (1967). See also Cottage Savings Assn. v. CommissionerSearch
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the marital bequest, was repeatedly rejected by the Tax Court and the Courts of Appeals. See, e. g., Estate of Street v. CommissionerSearch
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Estate of Whittle v. CommissionerSearch
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Estate of Richardson v. CommissionerSearch
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concurrence acknowledge, one component of an asset's value is its discounted future income. See, e. g., Maass v. HigginsSearch
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b) 2 The plurality's reference to Ithaca Trust Co. v. UnitedSearch
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argued that such a payment does reduce the value of the marital deduction. See, e. g., Ballantine v. TomlinsonSearch
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Alston v. UnitedSearch
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Estate of Street v. Commis-Search
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see United States v. StapfSearch
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see National Muffler Dealers Assn., Inc. v. UnitedSearch
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Syllabus Commissioner of Internal Revenue V. EstateSearch
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Cf. Ithaca Trust Co. v. UnitedSearch
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Estate of Street v. CommissionerSearch
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Burke v. UnitedSearch
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Ithaca Trust Co. v. UnitedSearch
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See Connecticut Nat. Bank v. GermainSearch
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Ballantine v. TomlinsonSearch
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United States v. MooreSearch
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Cottage Savings Assn. v. CommissionerSearch
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Maass v. HigginsSearch
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