context: This case is one of the "few instances" where death itself -- not distribution-- changes the value of property owned by the decedent.
citation_a.signal: no signal
citation_a.identifier: 674 F.2d 768, 768
citation_a.parenthetical: "[I]n a few instances ... death does change the value of the property."
citation_a.sentence: Ahmanson, 674 F.2d at 768 (“[I]n a few instances ... death does change the value of the property.”); see also Land, 303 F.2d at 172 (“It is only in the few cases where death alters value, as well as ownership, that it is necessary to determine whether the value at the time of death reflects the change caused by death____”). The majority resolves this case by relying on the familiar distinction between the estate tax (a tax on the passing of property) and the inheritance tax (a tax on the receipt of property by the decedent’s beneficiaries).
citation_b.signal: see also
citation_b.identifier: 303 F.2d 172, 172
citation_b.parenthetical: "It is only in the few cases where death alters value, as well as ownership, that it is necessary to determine whether the value at the time of death reflects the change caused by death____"
citation_b.sentence: Ahmanson, 674 F.2d at 768 (“[I]n a few instances ... death does change the value of the property.”); see also Land, 303 F.2d at 172 (“It is only in the few cases where death alters value, as well as ownership, that it is necessary to determine whether the value at the time of death reflects the change caused by death____”). The majority resolves this case by relying on the familiar distinction between the estate tax (a tax on the passing of property) and the inheritance tax (a tax on the receipt of property by the decedent’s beneficiaries).