Stamos v. Commissioner
United States Tax Court
Certain language of the stipulation filed herein pertaining to findings of fact set forth in related State court opinions determined to be ambiguous and conditional and therefore such language must be disregarded. Respondent's motion for partial summary judgment based in part on such language is denied. Other issues decided.
1Opinion of the Court
OPINION
SWIFT, Judge:
This matter is before the Court on petitioner’s motion for summary judgment and respondent’s motion for partial summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure. At issue are excise taxes and additions to tax in excess of $23 million.
The issues in this case arise out of the widely publicized and much litigated Estate of Mark Rothko (hereinafter sometimes referred to as the estate). Our recently filed opinion in Estate of Reis v. Commissioner, 87 T.C. 1016 (1986), also involved the Estate of Mark Rothko, excise taxes imposed by…
2Cases cited20 opinions
- United States v. Theodore Duane McKinneyCourt of Appeals for the Fifth Circuit · 1985
- Nishman v. De MarcoAppellate Division of the Supreme Court of the State of New York · 1980
- Rolland L. King and Arlene P. King v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Peter E. Blum and Robert S. Prather, Jr. v. Morgan Guaranty Trust Company of New YorkCourt of Appeals for the Eleventh Circuit · 1983
- Charles Fisher v. First Stamford Bank and Trust CompanyCourt of Appeals for the First Circuit · 1984
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3Cited by36 opinions
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Bankamerica Corp. v. CommissionerUnited States Tax Court · 1997
- Conklin v. CommissionerUnited States Tax Court · 1988
- Duncan v. Comm'rUnited States Tax Court · 2003
31 more not listed; retrieve them via the Exa API.