Legal Opinion

Illinois Masonic Home v. Commissioner

United States Tax Court

Decided August 2, 1989No. Docket No. 9010-87Published

An estate tax closing letter was mailed to the estate of Clara M. Evans indicating a final total Federal estate tax liability of $ 877,507.45. Pursuant to the terms of the will and after the period of limitations on assessment of additional estate tax against the estate expired, the executor distributed the assets of the estate to petitioners. The Commissioner subsequently determined an additional liability for estate tax.

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An estate tax closing letter was mailed to the estate of Clara M. Evans indicating a final total Federal estate tax liability of $ 877,507.45. Pursuant to the terms of the will and after the period of limitations on assessment of additional estate tax against the estate expired, the executor distributed the assets of the estate to petitioners. The Commissioner subsequently determined an additional liability for estate tax. The distribution of assets represents the transfers which the Commissioner has determined as giving rise to transferee liability. Held, the expiration of the period of…

1Opinion of the Court

Illinois Masonic Home, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Illinois Masonic Home v. Commissioner

Docket No. 9010-87

United States Tax Court

93 T.C. 145; 1989 U.S. Tax Ct. LEXIS 111; 93 T.C. No. 15;

August 2, 1989August 2, 1989, Filed

Decision will be entered for the petitioners.

An estate tax closing letter was mailed to the estate of Clara M. Evans indicating a final total Federal estate tax liability of $ 877,507.45. Pursuant to the terms of the will and after the period of limitations on assessment of additional estate tax against the estate expired, the executor…

2Cases cited8 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Mysse v. CommissionerUnited States Tax Court · 1972
  3. Schwager v. CommissionerUnited States Tax Court · 1975
  4. Phyllis Berliant, Transferee v. Commissioner of Internal Revenue, Florence Kraft, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
  5. Dillman v. CommissionerUnited States Tax Court · 1975

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