Estate of Lombard v. Commissioner
United States Tax Court
On Feb. 27, 1975, duplicate original notices of deficiency were mailed to the estate of decedent, a United States citizen domiciled in Panama where over 75 percent of her assets were located. One of the notices was addressed to the executor under decedent's will, which was probated in Panama, and the other to an administrator in Connecticut, where the rest of decedent's assets were located.
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On Feb. 27, 1975, duplicate original notices of deficiency were mailed to the estate of decedent, a United States citizen domiciled in Panama where over 75 percent of her assets were located. One of the notices was addressed to the executor under decedent's will, which was probated in Panama, and the other to an administrator in Connecticut, where the rest of decedent's assets were located. On July 24, 1975, the Connecticut administrator transmitted the estate's petition to this Court by certified mail. Held, under sec. 6213(a), I.R.C. 1954, decedent's estate had 150 days within which to file…
1Opinion of the Court
Estate of Bessie Deming Lombard, The Connecticut Bank and Trust Company, Administrator, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Lombard v. Commissioner
Docket No. 7030-75
United States Tax Court
66 T.C. 1; 1976 U.S. Tax Ct. LEXIS 135;
April 5, 1976, Filed
On Feb. 27, 1975, duplicate original notices of deficiency were mailed to the estate of decedent, a United States citizen domiciled in Panama where over 75 percent of her assets were located. One of the notices was addressed to the executor under decedent's will, which was probated in Panama, and the other to an…
2Cases cited8 opinions
- Commissioner of Internal Revenue v. New York Trust Co.Court of Appeals for the Second Circuit · 1931
- Estate of Krueger v. CommissionerUnited States Tax Court · 1960
- Mindell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Hamilton v. CommissionerUnited States Tax Court · 1949
- Cowan v. CommissionerUnited States Tax Court · 1970
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