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Jackson v. United States, 376 U.S. 503 (1964)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Jackson v. United States, 376 U.S. 503 (1964)
Jackson v. United States No. 361 Argued March 4, 1964 Decided March 23, 1964 376 U.S. 503
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
Syllabus
Fourteen months after her husband’s death, a state court awarded his widow a support and maintenance allowance payable monthly for not to exceed twenty-four months from date of decedent’s death. The widow survived the period, unremarried, and under state law was entitled to and did receive the payments. Deduction of all the payments on the federal estate tax return, as part of the marital deduction provided by § 812(e) of the Internal Revenue Code of 1939, was disallowed by the Commissioner of Internal Revenue. The District Court held that the widow’s allowance was a "terminable interest" under § 812(e)(1)(B), and thus not deductible, and the Court of Appeals affirmed.
Held:
1. Since a widow’ right to the allowance under the State law is defeated by her death or remarriage, her interest is terminable under § 812(e)(1)(B). Pp. 503-506.
2. Qualification for the marital deduction, including the widow’s allowance, is determined as of time of death. Cunha’s Estate v. Commissioner, 279 F.2d 292; United States v. Quivey, 292 F.2d 252, followed. Pp. 507-511.
317 F.2d 821, affirmed.
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Chicago: U.S. Supreme Court, "Syllabus," Jackson v. United States, 376 U.S. 503 (1964) in 376 U.S. 503 Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=JIKMPGBAGJKUF75.
MLA: U.S. Supreme Court. "Syllabus." Jackson v. United States, 376 U.S. 503 (1964), in 376 U.S. 503, Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=JIKMPGBAGJKUF75.
Harvard: U.S. Supreme Court, 'Syllabus' in Jackson v. United States, 376 U.S. 503 (1964). cited in 1964, 376 U.S. 503. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=JIKMPGBAGJKUF75.
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