Estate of Riegelman v. Commissioner
United States Court of Appeals for the Second Circuit
253 F.2d 315 (1958)
- Written by Tom Squier, JD
Facts
Charles Riegelman was a partner at a law firm when he died. The firm’s partnership agreement specified that if a partner died, the partnership would not be dissolved, but instead the deceased partner’s estate would receive payments from the firm. The payments would be for work that the partner had done before death and, for a specified period of time, a share of fees for work completed after the partner’s death, including both work attributable to the deceased partner’s efforts and work not attributable to the deceased partner. The executors of Riegelman’s estate (the estate) (plaintiff) filed an estate-tax return and included the post-death payments from the firm to the extent of fees attributable to Riegelman but did not include the income from fees that were not attributable to Riegelman as part of the gross estate. The Internal Revenue Service found the estate to be deficient and demanded that the gross estate also be taxed on the amount of the fees that were not attributable to Riegelman. The estate appealed to the United States Tax Court. The tax court upheld the IRS’s determination. The executors appealed.
Rule of Law
Issue
Holding and Reasoning (Waterman, J.)
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