Legal Opinion
Estate of Anthony Geraci, Deceased, Norma Geraci v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided September 5, 1974No. 74-1230PublishedCited by 35 opinions
1Per curiam
The sole issue in this appeal is whether the failure of an executrix to file a federal estate tax return within the prescribed time was due to reasonable cause and not due to willful neglect. Int. Rev. Code of 1954, § 6651(a).
At the time of the decedent’s death, March 27, 1967, a federal estate tax return was required to be filed “within 15 months after the date of the decedent’s death.” Int. Rev. Code of 1954, § 6075(a). The due date for the estate tax return in the present ease was, therefore, June 27, 1968. The decedent’s widow, the appellant on behalf of the estate, was appointed…
2Cases cited5 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Estate of Frank Duttenhofer, Deceased, Albert J. Uhlenbrock and William Duttenhofer, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- Duttenhofer v. CommissionerUnited States Tax Court · 1967
- In Re Fisk's Estate. Fisk v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
- Fidelity & Columbia Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1937
3Cited by35 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
- Estate of Rapelje v. CommissionerUnited States Tax Court · 1979
- Estate of Di Palma v. CommissionerUnited States Tax Court · 1978
- Jack C. Chilingirian Joann E. Chilingirian v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1990
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