ESTATE OF WALBURGA HEDRICK, DECEASED, AKA WALBURGA OESTERREICH, RAY BERT HEDRICK, EXECUTOR, PETITIONER,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
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PER CURIAM:
The decision of the Tax Court, pursuant to our Estate of Hedrick v. Commissioner of Internal Revenue, 406 F. 2d 587 (9th Cir., 1969), is affirmed.
On remand, the Tax Court, in reconstructing the transaction, adopted as to the Hedrick Estate a rate of 7%. This resulted in establishing an original sale value, as reconstructed of an amount about twice the actual cash value of the property at the time of sale.
We find the decision complies with our mandate. The present objections of the Hedrick Estate are primarily directed at our prior opinion, which has become the law of the eases.1
. Earlier decisions concerned with the same transaction are Oesterreich v. Commissioner of Internal Revenue, 226 F. 2d 798 (9th Cir. 1955), Commissioner of Internal Revenue v. Wilshire Holding Corp., 288 F. 2d 799 (9th Cir. 1961), and Estate of Hedrick v. Commissioner of Internal Revenue, 406 F. 2d 587 (9th Cir. 1969).
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Citator
Cited By
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Quincy Lairsey and Frances Lairsey v. The Advance Abrasives Co., 542 F.2d 928 (5th Cir. 1976)
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Ellie Marie Parks and Willis Eugene Parks v. U. S. Life & Credit Corp., 677 F.2d 838 (11th Cir. 1982)
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Sommer Corp. v. Panama Canal Co., 475 F.2d 292 (5th Cir. 1973)
Authorities Cited
- Walburga Oesterreich v. Commissioner OF Internal Revenue, 226 F.2d 798 (9th Cir. 1955)
- Commissioner OF Internal Revenue v. Wilshire Holding Corp., 288 F.2d 799 (9th Cir. 1960)
- Est. of Walburga Hedrick v. Commissioner OF Internal Revenue, 406 F.2d 587 (9th Cir. 1969)