Estate of Papson v. Commissioner
United States Tax Court
Decedent died in 1973 owning, inter alia, as a closely held business, a shopping center. In 1974, petitioner elected, pursuant to sec. 6166, I.R.C. 1954, to pay its outstanding estate tax liability on the installment method. In 1975, Congress changed the interest rate from 4 percent to a higher variable rate, effective July 1, 1975. Held, the higher variable rate applies to the installments due from petitioner from and after that day.
Read the full summary
Decedent died in 1973 owning, inter alia, as a closely held business, a shopping center. In 1974, petitioner elected, pursuant to sec. 6166, I.R.C. 1954, to pay its outstanding estate tax liability on the installment method. In 1975, Congress changed the interest rate from 4 percent to a higher variable rate, effective July 1, 1975. Held, the higher variable rate applies to the installments due from petitioner from and after that day. Held, further, the rate change did not violate any of petitioner's constitutional rights.
1Opinion of the Court
Estate of Leonidas C. Papson, Deceased, Costa L. Papson, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Papson v. Commissioner
Docket No. 10249-76
United States Tax Court
81 T.C. 105; 1983 U.S. Tax Ct. LEXIS 55; 81 T.C. No. 9;
August 17, 1983, Filed
Decision will be entered in accordance with respondent's Rule 155 computation.
Decedent died in 1973 owning, inter alia, as a closely held business, a shopping center. In 1974, petitioner elected, pursuant to sec. 6166, I.R.C. 1954, to pay its outstanding estate tax liability on the installment method. In 1975, Congress…
2Cases cited26 opinions
- Usery v. Turner Elkhorn Mining Co.Supreme Court of the United States · 1976
- Lynch v. United StatesSupreme Court of the United States · 1934
- Reisman v. CaplinSupreme Court of the United States · 1964
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Welch v. HenrySupreme Court of the United States · 1938
21 more not listed; retrieve them via the Exa API.