- 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).
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