Legal Opinion

Estate of Smith v. Commissioner

United States Tax Court

Decided January 12, 1998No. Tax Ct. Dkt. No. 19200-94; Docket No. 3976-95PublishedCited by 19 opinions

1Opinion of the Court

SUPPLEMENTAL OPINION

Ruwe, Judge:

On June 4, 1997, we issued our opinion in these consolidated cases. Estate of Smith v. Commissioner, 108 T.C. 412 (1997). Pursuant to that opinion, the parties filed separate computations pursuant to Rule 155.1 These cases are before the Court again because the parties cannot agree on the proper method for computing the overpayment of income tax and the deficiency in estate tax.2

The issues presented concern: (1) The proper method for computing an income tax credit and resulting overpayment under section 1341(a)(5) and (b),3 and (2) whether respondent may now…

2Cases cited2 opinions

  1. Jess Kraft and Barbara Kraft v. United StatesCourt of Appeals for the Sixth Circuit · 1993
  2. Estate of Smith v. CommissionerUnited States Tax Court · 1997

3Cited by19 opinions

  1. Marshall M. Chernin Ida Raye Chernin, Cross-Appellants/appellees v. United States of America, Appellant/cross-AppelleeCourt of Appeals for the Eighth Circuit · 1998
  2. Estate of Smith v. Comm'rUnited States Tax Court · 2004
  3. Schortmann v. United StatesUnited States Court of Federal Claims · 2008
  4. Estate of Smith v. CommissionerUnited States Tax Court · 2000
  5. Estate of Smith v. Comm'rUnited States Tax Court · 2001

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