Legal Opinion
United States v. Gordon Simmons and I. v. Simmons, Executors of the Estate of B. Hill Simmons
Court of Appeals for the Fifth Circuit
Decided May 27, 1965No. 21464_1PublishedCited by 61 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
This taxpayer’s suit for an estate tax refund grew out of executors’ settling for $42,000 an estate’s claim for an income tax refund of $60,000, listed in the estate tax return as having “no value” at the date of the decedent’s death.
The decedent, B. Hill Simmons, died December 27, 1955. Some time before his death, the Internal Revenue Service began investigating, on a net worth basis, Simmons’s income tax returns for the years 1941 through 1953. As a result of the investigation, the decedent paid a deficiency in the amount of $43,000. The decedent never entertained the…
2Cases cited8 opinions
- Commissioner of Internal Revenue v. MarshallCourt of Appeals for the Second Circuit · 1942
- Bank of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1943
- Rose v. United StatesCourt of Appeals for the Tenth Circuit · 1942
- Commissioner of Internal Revenue v. Estate of Carlton A. Shively, Deceased, John E. D. Grunow, AdministratorCourt of Appeals for the Second Circuit · 1960
- Dr. C. Grenes Cole and Mrs. Hallette B. Cole v. Chester A. Usry, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
3 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Jamison Co. v. Westvaco Corp.Court of Appeals for the Fifth Circuit · 1976
- Estate of Bernard Curry, Union Bank and Trust of New Albany, Trustee v. United StatesCourt of Appeals for the Seventh Circuit · 1983
- Estate of Spruill v. CommissionerUnited States Tax Court · 1987
56 more not listed; retrieve them via the Exa API.