Untitled Texas Attorney General Opinion

Honorable Robert S, Ca1ver.t 0Di.nior-l No. M-88 ComptrcL:er of Pdbiic Accounts Re: Taxability for Inheritance Capitc3.Station Tax pu;*pCSeS of succession Austin, Texas 7871.X t@ real prCperty by surviv- ing joint tenant under sub- Dear Mr. Ca1ver.t: mitted facts. We quote the following excerpt from your letter request- ing the opinion of this Office on the above captioned subject: 9, . . 0 [Mrs. X] died testate, a resident of Dallas County, on February 6, 1966, and the proper repcrts have been submitted to this Department for an inheritance tax clearance. II [ x ] and his wife, [Mrs. Z?];'eAteredinto a jcir:ttei:a& agreement in 1959 wit!3 ~ D D [Miss rj in ccncectiun with the o-w??ershI~pof a house and lot located i;IDallas County, Texas 9 having a value of $19,500.00. [ X ] predeceased his wife, . , . tl& : X],and . . [Miss Y] is now the sole SU~~V~.VC~oh this Jc,int Tenancy Agreement,. "Your Department has passed on a similar question in Opkion No. WW-262, and we wish to be advised whether gr not this opinion ,is applicable in ifniscase, - 399 - Honorable Rcbcrt S. Calve&, Page 2 (N-88) The ps:?tine;;t are the foIlewing: !!,;. * "Now, premzses and the sum of One Dollar ($1.00) and other gicd and -zal:lab>ecc;isaid.r:~~i;icrs by each of the .unders;gnedparties heretc to the other in hand paid? receipt .wiiex?cf’ is hereby ackncw- ledged by each party and -thefl:rtherconsidera- tion of the ml.tual u1 benefits ae.c?Une L to the LB' undersigned, and parties hereto, it is agreed as follows: Honorable Robert S. Calvert, Page 3 (K-08) considered, the surviving joint tenants did not owe any inheri- tance tax upon the interest received at the death of a joint tenant. Those facts were that a third party, by deed, created a joint tenancy with right of survivorship in four named parties, In view of the fact that the joint tenants had not by agreement created the joint tenancy with right of survivorship, we held that there was no taxable succession to the property under the provisiona of the then Article 7117, Volume 20, Vernon's Civil Statutes, which imposed an inheritance tax upon property pass- ing by "deed, grant, sale or gift made or intended to take effect in possession or enjoyment after the death of the grantor or donor . . . ." This Office has held that where the joint tenancy with right of survivorship is created by an express agreement between the parties, at the death of a joint tenant the passing of his or her interest is subject to inheritance tax. In Attorney General Opinion No. C-12 (1963), it was held that one-half of the value of United States government bonds of the cc-ownership type, purchased with community funds and payable to husband or wife, was subject to an inheritance tax upon the death of the husband. This opinion contains a rather lengthy analysis of the treatment for inheritance tax purposes of bonds of this type. In this case, we are not confronted with the effect of the agreement submitted to us in so far as it purports tc effectuate a partition of the community interest of the spouses, as was the case under consideration in Attcrney General Opinion No. WV-1013 (1961). Under the express terms of the submitted agreement, the spouses1 former interest in the land in question, as a joint tenant with right of survivorship, was specifically required upon the death of the last of the spouses, to pass to the now sole survivor of the joint tenancy. We do.not think that there can be any valid distinction fcr inheritance tax purposes because the property under consideration is real prop- erty rather than personalty. You are therefore advised that upon the death of the decedent in this case, there was a taxable succession to he.rthen one-half interest in the joint tenancy . l/ Presently carried as Article 14.01, Ch. 14, Title 122A, Tax.-Gen., V.C.S. - 401 - , Honorable Robert S. cd~cd, page 4 (~-88) by virtue of the provision above quoted, which taxes transfers intended to take effect in possess. ion or enjoyment at the death of the decedent. S UMMA R Y Where spouses and third party created by express contract a valid joint tenancy with right of survivorship and the spouses predeceased the third party joint tenar,t,under the provisions of Article 14.01, Ch. 14, Title 122A, Tax.-Gen., V.C.S., an inheritance tax accrued upon the pass- ing of the surviving spouse's interest at the time of the death of said surviving spouse. Prepared by Marietta McGregor Payne Assistant Attorney General MMP/fb . APPROVED: OPINION COMMITTEE Hawthorne Phillips, Chairman W. V. Geppert, Co-Chairman Ralph Rash Arthur Sandlin W. E. Allen Pat Bailey STAFF LFGAL ASSISTANT A. J. Carubbi, Jr. . - 402 -