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Estate of Goldsborough v. Commissioner

United States Tax Court
70 T.C. 1077 (1978)

Written by Angela Patrick, JD

Facts

Marcia Goldsborough gave her two daughters a gift of real estate worth $25,000. Three years later, the daughters sold the real estate for $32,500. The daughters then used the $32,500 in sale proceeds to buy stock and added Goldsborough to the stock titles, making Goldsborough a joint owner of all the purchased stock. When Goldsborough died, the stock was worth approximately $160,000. The commissioner of Internal Revenue (commissioner) (defendant) claimed that the stock came directly from a gift from Goldsborough and, therefore, that the entire $160,000 value was a taxable part of Goldsborough’s gross estate under 26 U.S.C. § 2040. Goldsborough’s estate (plaintiff) petitioned the United States Tax Court for a determination that (1) $7,500 of the stock’s purchase had been contributed by the daughters, not Goldsborough, through the daughters’ profit from the real estate sale and (2) the estate was entitled to exclude the portion of the stock’s value that was attributable to the daughters’ contribution, which was 7,500/32,500 of $160,000, or approximately $37,000.

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Holding and Reasoning (Featherston, J.)

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