Estate of Kahn v. Comm'r
United States Tax Court
The estate filed Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return ("estate tax return"). R issued a notice of deficiency that inter alia asserted increases to the gross estate by disallowing a reduction in value of P's individual retirement accounts (IRAs) by the expected Federal income tax liability resulting from the distribution of the IRAs' assets to the beneficiaries under sec. 408(d)(1), I.R.C.
Read the full summary
The estate filed Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return ("estate tax return"). R issued a notice of deficiency that inter alia asserted increases to the gross estate by disallowing a reduction in value of P's individual retirement accounts (IRAs) by the expected Federal income tax liability resulting from the distribution of the IRAs' assets to the beneficiaries under sec. 408(d)(1), I.R.C. (income tax liability). This matter is before us on P's motion for partial summary judgment under Rule 121(a), contesting R's disallowance of the reduction in the value of the…
1Opinion of the Court
OPINION
Goeke, Judge:
This matter is before the Court on cross-motions for summary judgment under Rule 121(a).1
Respondent issued a notice of deficiency in the Federal estate tax of the estate of decedent Doris F. Kahn (the estate), determining, among other adjustments, that the estate had undervalued two IRAs on the estate’s Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return. The issue before us is whether the estate may reduce the value of the two IRAs included in the gross estate by the anticipated income tax liability that would be incurred by the designated beneficiary upon…
2Cases cited32 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- United States v. CartwrightSupreme Court of the United States · 1973
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
27 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Estate of Jelke v. CommissionerCourt of Appeals for the Eleventh Circuit · 2007
- Estate of Roski v. Comm'rUnited States Tax Court · 2007
- Chilton v. MoserCourt of Appeals for the Fifth Circuit · 2012
- RSW Enterprises, Inc. v. CommissionerUnited States Tax Court · 2014
- r2 Advisors, LLC v. Equitable Oil Purchasing Co. (In re Red Eagle Oil, Inc.)United States Bankruptcy Court, D. Wyoming · 2017
18 more not listed; retrieve them via the Exa API.