Estate of Doris F. Kahn, Deceased, LaSalle Bank, N.A., Trustee and Executor - Page 31

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          examined the issue of whether to discount the value of                      
          installment notes in decedent’s estate for future income taxes              
          that the beneficiaries of those notes would pay on the income in            
          respect of a decedent included in future installments.  We                  
          determined that the statutory scheme in section 691 obviated the            
          need to give the taxpayer any further relief.  Id. at 226.                  
          Section 691(a)(1) provides that “all items of gross income in               
          respect of a decedent * * *shall be included in the gross income,           
          for the taxable year when received”.  Section 691(a)(3) provides            
          that such income in the hands of the person acquiring a right to            
          it from decedent will be treated in the same manner as it would             
          have been in the hands of decedent.  We noted that if the statute           
          stopped here, installment notes transmitted by a decedent at his            
          death would be included in decedent’s estate at the fair market             
          value provided under sections 2031 and 2033, and each portion of            
          the future installment payments which represented taxable gain              
          would be subject to an income tax in the year of receipt.  Id. at           
          226.  However, we further observed that section 691(c) grants               
          some relief from the double taxation by providing that the                  
          recipient of income in respect of a decedent may deduct that                
          portion of the estate tax levied on decedent’s estate which is              
          attributable to the inclusion of the right to such income in                
          decedent's estate.  We concluded therefore in Estate of Robinson            
          v. Commissioner, supra at 226-227:                                          






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