Estate of Wilbanks v. Commissioner
United States Tax Court
Held: Petitioner's motion for summary judgment, as amended, will be denied. Respondent's cross-motion for summary judgment will be granted in part, and denied in part.
1Opinion of the Court
OPINION
WHITAKER, Judge:
This case is before us on petitioner’s motion for summary judgment, as amended, and respondent’s cross-motion for summary judgment. In his notice of deficiency, respondent determined an addition to petitioner’s Federal estate tax under section 6651(a)(1)1 in the amount of $54,964.86. Both parties have moved for summary adjudication in their favor on the issue of whether petitioner is hable for the section 6651(a)(1) addition to tax. As a preliminary matter, however, we must decide: (1) Whether respondent abused his discretion by not approving petitioner’s application…
2Cases cited20 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Naftel v. CommissionerUnited States Tax Court · 1985
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Espinoza v. CommissionerUnited States Tax Court · 1982
15 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Estate of Charania v. Comm'rUnited States Tax Court · 2009
- Estate of Wilbanks v. CommissionerUnited States Tax Court · 1991
- Cantrell v. Comm'rUnited States Tax Court · 2017
- Codington County Humane Soc. v. CommissionerUnited States Tax Court · 1991
- Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
5 more not listed; retrieve them via the Exa API.