Groetzinger v. Commissioner
United States Tax Court
Petitioners are transferees of the assets of an estate. The estate had timely filed its Federal estate tax return and, after certain adjustments, paid its estate tax together with all deficiencies. Subsequently, respondent refunded the bulk of those taxes. The refund was made without the taxpayer estate's request for it but because respondent erroneously posted the estate's payments of its taxes.
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Petitioners are transferees of the assets of an estate. The estate had timely filed its Federal estate tax return and, after certain adjustments, paid its estate tax together with all deficiencies. Subsequently, respondent refunded the bulk of those taxes. The refund was made without the taxpayer estate's request for it but because respondent erroneously posted the estate's payments of its taxes. Respondent determined the liabilities of petitioners as transferees in the amounts transferred to them. Held, the refund was not a rebate within the meaning of sec. 6211(b)(2), but was an…
1Opinion of the Court
OPINION
Tietjens, Judge:
Respondent determined a deficiency in the Federal estate tax of the Estate of Nancy W. Groezinger in the amount of $19,667.74 and determined the following liabilities of petitioners as transferees of the estate:
Petitioner Liability
Walker Groetzinger .$8,316.92
Sara H. Groezinger .8,316.92
The issues are whether this Court has jurisdiction over the petitions and, if so, whether petitioners are liable as transferees in the amounts received.
This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and attached…
2Cases cited12 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. SternSupreme Court of the United States · 1958
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
7 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Raymond E. And Dorothy J. O'Bryant v. United StatesCourt of Appeals for the Seventh Circuit · 1995
- Pesch v. CommissionerUnited States Tax Court · 1982
- Richard M. Baptiste, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- Clark v. United StatesCourt of Appeals for the First Circuit · 1995
- Long v. CommissionerUnited States Tax Court · 1978
39 more not listed; retrieve them via the Exa API.