Estate of Gardner v. Commissioner
United States Tax Court
P's attorney requested an extension to file P's estate tax return 11 days after the due date of the return. After the return was filed R rejected the request for extension.
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P's attorney requested an extension to file P's estate tax return 11 days after the due date of the return. After the return was filed R rejected the request for extension. Held, even if R abused his discretion in failing to investigate and objectively review the explanations contained in petitioner's extension request, based on the record, no good and sufficient cause existed for an extension of time to file, and accordingly the estate tax return cannot be considered as having been timely filed. Held,further, the estate does not qualify for section 2032A "special use" valuation.…
1Opinion of the Court
ESTATE OF SHELLA B. GARDNER, DECEASED, OMER MACY, ADMINISTRATOR, WITH WILL ANNEXED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Gardner v. Commissioner
Docket No. 28332-83.
United States Tax Court
T.C. Memo 1986-380; 1986 Tax Ct. Memo LEXIS 224; 52 T.C.M. (CCH) 202; T.C.M. (RIA) 86380;
August 18, 1986.
P's attorney requested an extension to file P's estate tax return 11 days after the due date of the return. After the return was filed R rejected the request for extension.
Held, even if R abused his discretion in failing to investigate and objectively review the explanations…
2Cases cited11 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Foster v. Comm'rUnited States Tax Court · 1983
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Ballentine Motor Co. v. CommissionerUnited States Tax Court · 1962
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
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