Estate of Hughey v. Commissioner
United States Tax Court
R determined an income tax deficiency against an estate, directing the notice of deficiency to the executor (E). The estate was closed and all assets had been distributed to the beneficiary (B) prior to the issuance of the notice of deficiency. Held, B cannot file a petition as he is not an authorized representative of the estate.
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R determined an income tax deficiency against an estate, directing the notice of deficiency to the executor (E). The estate was closed and all assets had been distributed to the beneficiary (B) prior to the issuance of the notice of deficiency. Held, B cannot file a petition as he is not an authorized representative of the estate. Held further, that B is not an executor within the meaning of section 2203. Held further, that there has been no ratification of the original petition. Held further, that this matter is dismissed for lack of jurisdiction.
1Opinion of the Court
ESTATE OF ELDEAN W. HUGHEY, FIRST NATIONAL BANK AND TRUST COMPANY, FIDUCIARY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Hughey v. Commissioner
Docket No. 29435-86.
United States Tax Court
T.C. Memo 1987-383; 1987 Tax Ct. Memo LEXIS 381; 54 T.C.M. (CCH) 41; T.C.M. (RIA) 87383;
August 4, 1987.
R determined an income tax deficiency against an estate, directing the notice of deficiency to the executor (E). The estate was closed and all assets had been distributed to the beneficiary (B) prior to the issuance of the notice of deficiency. Held, B cannot file a petition as he is…
2Cases cited15 opinions
- Krueger v. CommissionerUnited States Tax Court · 1967
- Carstenson v. CommissionerUnited States Tax Court · 1972
- Fehrs v. CommissionerUnited States Tax Court · 1975
- Harold Patz Trust v. CommissionerUnited States Tax Court · 1977
- Hoj v. CommissionerUnited States Tax Court · 1956
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