Huddleston v. Commissioner
United States Tax Court
These consolidated cases involve, among other things, petitioner Albert J. Huddleston's personal liability as a fiduciary under sec. 6901, I.R.C. 1954, as amended, and 31 U.S.C. sec. 3713(b) (1982), with regard to the Federal estate tax deficiency of his deceased wife's estate and the fraud addition to tax.
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These consolidated cases involve, among other things, petitioner Albert J. Huddleston's personal liability as a fiduciary under sec. 6901, I.R.C. 1954, as amended, and 31 U.S.C. sec. 3713(b) (1982), with regard to the Federal estate tax deficiency of his deceased wife's estate and the fraud addition to tax. After filing the Federal estate tax return on behalf of his deceased wife's estate and after representing the estate as its personal representative before respondent's Internal Revenue Service and before this Court in Estate of Madeline S. Huddleston, Deceased, Albert J. Huddleston,…
1Opinion of the Court
OPINION
Swift, Judge:
This matter is now before us on petitioner Albert J. Huddleston’s (petitioner)2 motion for summary judgment.
The underlying issue in these consolidated cases is the correctness of respondent’s determination that petitioner is liable as a fiduciary under section 69013 with respect to a $345,147 deficiency in the Federal estate tax of the Estate of Madeline S. Huddleston (decedent), and with respect to the related $172,573 fraud addition to tax under section 6653(b).
The estate’s Federal estate tax liability and the related fraud addition to tax were at issue in this Court in…
2Cases cited27 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Huffman v. Pursue, Ltd.Supreme Court of the United States · 1975
- Davis v. WakeleeSupreme Court of the United States · 1895
- Chrysler Credit Corp. v. Country Chrysler, Inc.Court of Appeals for the Tenth Circuit · 1991
- Scarano v. Central R. Co. Of New JerseyCourt of Appeals for the Third Circuit · 1953
22 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- MAGGIE MGMT. CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1997
- Fort Howard Corp. v. CommissionerUnited States Tax Court · 1994
- Fazi v. CommissionerUnited States Tax Court · 1995
- Estate of Mueller v. CommissionerUnited States Tax Court · 1996
- Pert v. CommissionerUnited States Tax Court · 1995
34 more not listed; retrieve them via the Exa API.