Greenoak Holdings Ltd. v. Comm'r
United States Tax Court
R issued a final notice of intent to levy to estate (E) to collect unpaid estate tax. E requested a hearing before an IRS Appeals officer (AO) pursuant to I.R.C. sec. 6330. Following the hearing, AO issued a notice of determination to E sustaining the proposed levy as to E's nonprobate assets.
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R issued a final notice of intent to levy to estate (E) to collect unpaid estate tax. E requested a hearing before an IRS Appeals officer (AO) pursuant to I.R.C. sec. 6330. Following the hearing, AO issued a notice of determination to E sustaining the proposed levy as to E's nonprobate assets. Among the nonprobate assets reported on the estate tax return was an offshore trust that owned certain entities (Ps). Ps petitioned the Tax Court for review of the notice of determination issued to E. No petition was filed on behalf of E. R moved to dismiss for lack of jurisdiction. Held: The "person"…
1Opinion of the Court
Ruwe, Judge:
Respondent issued a notice of determination to the personal representative of the Estate of James B. Irwin on May 1, 2013. Greenoak Holdings Limited, Southbrook Properties Limited, and Westlyn Properties Limited (petitioners) filed a petition for judicial review with the Tax Court on May 30, 2013. The issues for decision are: (1) whether petitioners’ alleged ownership interest in property that might be subject to levy by respondent entitles them to the rights afforded to “persons” under section 63301 and (2) whether this Court has jurisdiction under section 6330(d) of an appeal…
2Cases cited15 opinions
- K Mart Corp. v. Cartier, Inc.Supreme Court of the United States · 1988
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
- Murphy v. Comm'rUnited States Tax Court · 2005
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3Cited by3 opinions
- Greenberg v. Comm'rUnited States Tax Court · 2016
- Greenoak Holdings Limited, Southbrook Properties Limited and Westlyn Properties Limited v. CommissionerUnited States Tax Court · 2014
- Greenoak Holdings Ltd. v. Comm'rUnited States Tax Court · 2014