Hunt v. Comm'r of Internal Revenue (In re Estate of Hunt)

1 Citing case

  1. Prell v. Comm'r of Internal Revenue (In re Estate of Prell)

    48 T.C. 67 (U.S.T.C. 1967)   Cited 3 times

    With regard to the question of reasonableness, there is no positive rule which we can rely on for this determination since each case rests on its own facts. Some of the factors most often relied upon by the courts when considering the reasonableness of attorney's fees in estate cases are the size and nature of the estate, Estate of Charlotte D. M. Cardeza, 5 T.C. 202, 221(1945), affd. 173 F.2d 19(1949); Irving Bank-Columbia Trust Co., et al., Executors, 16 B.T.A. 897, 906(1929), the amount of work involved, Estate of E. W. Hunt, 11 T.C. 984, 992(1948), actual and contemplated litigation, Estate of E. W. Hunt, supra, Irving Bank-Columbia Trust Co., et al., Executors, supra, and the length of time the estate was under administration, Irving Bank-Columbia Trust Co., et al., Executors, supra. While we are without sufficient evidence to apply all the foregoing criteria to the instant situation, we think it significant that the value of decedent's gross estate at the time of his death was almost $5 1/2 million.