Goodman v. Granger
United States Court of Appeals for the Third Circuit
243 F.2d 264 (1957)
- Written by Daniel Clark, JD
Facts
Gimbel Brothers, Inc. (Gimbels) employed Jacques Blum in its Pittsburgh store. Blum and Gimbels negotiated employment contracts that, in addition to providing for an annual salary, provided for certain contingent payments to Blum’s estate or otherwise to a designee if Blum were to die. Blum died, and Gimbels began making the contingent payments to the executor of his estate (plaintiff). The executor did not include the present value of remaining contingent payments in Blum’s gross estate, claiming that those contingent payments were not included in the contracts’ value immediately before Blum’s death. The Internal Revenue Service (IRS) (defendant) assessed deficiencies, claiming that the value of the contracts includable in Blum’s gross estate included the value of the contingent payments that became obligatory upon Blum’s death. The executor brought suit in district court, which ruled in favor of the executor. The IRS appealed.
Rule of Law
Issue
Holding and Reasoning (Kalodner, J.)
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