Legal Opinion

Estate of Smith v. Commissioner

United States Tax Court

Decided October 18, 2000No. 19200-94; No. 3975-95Published

In a prior opinion, we determined that there was a deficiency in estate tax. P filed a timely notice of appeal but did not file a bond to stay assessment or collection during the pendency of the appeal. R assessed the deficiency in estate tax, and P paid a portion of the amount assessed. The Court of Appeals reversed, vacated, and remanded for further proceedings.

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In a prior opinion, we determined that there was a deficiency in estate tax. P filed a timely notice of appeal but did not file a bond to stay assessment or collection during the pendency of the appeal. R assessed the deficiency in estate tax, and P paid a portion of the amount assessed. The Court of Appeals reversed, vacated, and remanded for further proceedings. The Court of Appeals opinion did not preclude the possibility that further proceedings in this Court might result in an estate tax deficiency in the same amount that was previously decided. P filed a Motion To Restrain Collection,…

1Opinion of the Court

ESTATE OF ALGERINE ALLEN SMITH, DECEASED, JAMES ALLEN SMITH, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Smith v. Commissioner

No. 19200-94; No. 3975-95

United States Tax Court

115 T.C. 342; 2000 U.S. Tax Ct. LEXIS 75; 115 T.C. No. 27;

October 18, 2000, Filed

An appropriate order will be issued denying petitioner's motion.

In a prior opinion, we determined that there was a

deficiency in estate tax. P filed a timely notice of appeal but

did not file a bond to stay assessment or collection during the

pendency of the appeal. R assessed the deficiency in estate tax,

and P…

2Cases cited13 opinions

  1. Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
  2. Transpac Drilling Venture 1982-12, Guy J. Cutili v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
  3. Smith Ex Rel. Estate of Smith v. CommissionerCourt of Appeals for the Fifth Circuit · 1999
  4. Estate of Smith v. CommissionerUnited States Tax Court · 1997
  5. John J. Tyne, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1967

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