Little v. Commissioner
United States Tax Court
P was the personal representative of D's estate. During administration of the estate, P received information indicating possible income tax liabilities of the estate. P gave this information to the estate's lawyer, who erroneously and repeatedly advised P that the estate had no tax liabilities and advised P to make disbursements and distributions.
Read the full summary
P was the personal representative of D's estate. During administration of the estate, P received information indicating possible income tax liabilities of the estate. P gave this information to the estate's lawyer, who erroneously and repeatedly advised P that the estate had no tax liabilities and advised P to make disbursements and distributions. P, acting in good faith, followed this advice and eventually closed the estate without paying the estate's income tax liabilities. R determined that P is liable for the estate's unpaid income tax liabilities under 31 U.S.C. sec. 3713(b) (1994),…
1Opinion of the Court
WILLIAM D. LITTLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Little v. Commissioner
No. 24598-97
United States Tax Court
113 T.C. 474; 1999 U.S. Tax Ct. LEXIS 59; 113 T.C. No. 31;
December 29, 1999, Filed
Decision will be entered for petitioner.
P was the personal representative of D's estate. During
administration of the estate, P received information indicating
possible income tax liabilities of the estate. P gave this
information to the estate's lawyer, who erroneously and
repeatedly advised P that the estate had no tax liabilities and
advised P to make disbursements and…
2Cases cited8 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Estelle Want, Trustee and Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Leigh v. CommissionerUnited States Tax Court · 1979
- United States v. A. D. CrockerCourt of Appeals for the Ninth Circuit · 1963
- Irving Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
3 more not listed; retrieve them via the Exa API.