- 31 - Multiplied by decedent’s interest in CSB 71.43% Decedent’s pro rata share of CSB’s earned but unpaid profits 897,594 907,594 15-percent control premium 136,139 Respondent’s concession (see supra n.6) 62,029 Value of decedent’s CSB stock 1,105,762 F. Income in Respect of a Decedent Section 691(a)(1)(A) provides, in pertinent part, as follows: SEC. 691(a). Inclusion in Gross Income. (1) General Rule.--The amount of all items of gross income in respect of a decedent which are not properly includible in respect of the taxable period in which falls the date of his death or a prior period * * * shall be included in the gross income, for the taxable year when received, of: (A) the estate of the decedent, if the right to receive the amount is acquired by the decedent's estate from the decedent; Section 691 and its predecessor, section 126 of the Internal Revenue Code of 1939, were enacted to accomplish the general purpose of the Internal Revenue Code that a tax should be paid on all income and “that death should not rob the United States of the revenue which otherwise it would have had.” Linde v. Commissioner, 213 F.2d 1, 5 (9th Cir. 1954), remanding 17 T.C. 584 (1951).Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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