Estate of Owen v. Commissioner
United States Tax Court
Decedent died on Oct. 2, 1986. Decedent made gifts in 1984 and before death in 1986. Petitioner paid Kansas State inheritance tax on account of substantially all of these gifts. After decedent's death, there were found in his car checks that had been written by him during the 2 weeks before his death.
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Decedent died on Oct. 2, 1986. Decedent made gifts in 1984 and before death in 1986. Petitioner paid Kansas State inheritance tax on account of substantially all of these gifts. After decedent's death, there were found in his car checks that had been written by him during the 2 weeks before his death. Petitioner underreported the value of two bank accounts on its Federal estate tax return by the amount of these checks. 1. Held, the underreporting of the value of a bank account can be a valuation understatement within the meaning of sec. 6660, I.R.C. 1954. 2. Held, further, petitioner is not…
1Opinion of the Court
Chabot, Judge:
Respondent determined a deficiency in Federal estate tax and additions to tax under sections 6653(a)1 (negligence, etc.), 6653(b) (fraud), and 6660 (valuation understatement) against petitioner as follows:
Additions to tax
Sec. Sec. Deficiency 6653(a)(1)(A) 6653(a)(1)(B) Sec. Sec. 6653(b)(1)(A) 6653(b)(1)(B) Sec. 6660
$101,960 $3,933.62 50 percent of the interest on $78,672.45, the part of the underpayment attributable to negligence, etc. $9,287.71 50 percent of $7,552 the interest on $12,383.62, the part of the underpayment attributable to fraud
In the answer, respondent concedes…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Commissioner v. Keystone Consolidated Industries, Inc.Supreme Court of the United States · 1993
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
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3Cited by8 opinions
- Klaassen v. CommissionerUnited States Tax Court · 1998
- Estate of Heckert v. State Board of EqualizationWyoming Supreme Court · 2000
- Estate of Owen v. CommissionerUnited States Tax Court · 1995
- James A. Rochelle v. CommissionerUnited States Tax Court · 2001
- James A. Rochelle v. CommissionerUnited States Tax Court · 2001
3 more not listed; retrieve them via the Exa API.