Billhartz v. Commissioner

FLAUM, Circuit Judge.

Warren Billhartz left over $20 million to his four children when he died. When his Estate filed its estate tax return with the IRS, it claimed a deduction for a large portion of that amount — over $14 million. The IRS disallowed the deduction in full and issued the estate a notice of deficiency. The Estate then petitioned the United States Tax Court for redetermination of the deficiency, and a trial date was set. Before trial, though, the Estate and the Commissioner of Internal Revenue (“Commissioner”) agreed to a settlement, under which the Commissioner conceded 52.5% of…