Estate of Krampf v. Commissioner
United States Tax Court
1. Held, the petitioner is not entitled to an estate tax marital deduction with respect to property received by the survivor of a joint will. Estate of Edward N. Opal, 54 T.C. 154 (1970), on appeal (C.A. 2, Aug. 14, 1970), followed. 2. Held, the penalty due under sec. 6651(a) for failure to file a return must be based on correct tax liability rather than on the amount of tax shown to be due on the return. C. Fink Fischer, 50 T.C. 164 (1968).
1Opinion of the Court
OPINION
Quealy, Judge:
The respondent determined a deficiency in the Federal estate tax of the Estate of Saul Krampf in the amount of $15,637.64, together with an addition to the tax under section 6651 (a)1 in the amount of $781.89. Petitioner is the executrix of the estate.
The issues presented by the parties for decision are:(1) Whether the petitioner is entitled to a marital deduction under section 2056 for the value of the interest in property passing to Ida Krampf under the terms of the j oint will of Saul and Ida Krampf; and(2) Whether the petitioner is liable for an addition to tax under…
2Cases cited5 opinions
- Fischer v. CommissionerUnited States Tax Court · 1968
- Estate of Opal v. CommissionerUnited States Tax Court · 1970
- Tooker v. VreelandNew Jersey Court of Chancery · 1921
- Estate of Vermilya v. CommissionerUnited States Tax Court · 1963
- Sellyei v. LecsoNew Jersey Superior Court Appellate Division · 1953
3Cited by10 opinions
- Carnegie Productions, Inc. v. CommissionerUnited States Tax Court · 1973
- Estate of Saul Krampf, Deceased, Ida Krampf v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1972
- Estate of Abruzzino v. CommissionerUnited States Tax Court · 1973
- Estate of Siegel v. CommissionerUnited States Tax Court · 1977
- Carnegie Productions, Inc. v. CommissionerUnited States Tax Court · 1973
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