Legal Opinion

Werbelovsky v. Commissioner

United States Tax Court

Decided October 15, 1947No. Docket No. 10363Published

Petitioners did not file estate tax return until the expiration of two years and ten months after the date of decedent's death. Upon the facts it is held that the failure to file the return within the prescribed time was not due to reasonable cause.

1Opinion of the Court

Estate of Abraham Werbelovsky, Samuel Small, Rose Small and Everett Stein, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent

Werbelovsky v. Commissioner

Docket No. 10363

United States Tax Court

9 T.C. 689; 1947 U.S. Tax Ct. LEXIS 64;

October 15, 1947, Promulgated

Decision will be entered under Rule 50.

Petitioners did not file estate tax return until the expiration of two years and ten months after the date of decedent's death. Upon the facts it is held that the failure to file the return within the prescribed time was not due to reasonable cause.

Sylvester Benjamin, Esq., for…

2Cases cited4 opinions

  1. Curie v. CommissionerUnited States Tax Court · 1945
  2. Fairfax Mut. Wood Products Co. v. CommissionerUnited States Tax Court · 1945
  3. Forbes v. McHughMassachusetts Supreme Judicial Court · 1890
  4. Werbelovsky v. CommissionerUnited States Tax Court · 1947

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