Leigh v. Commissioner
United States Tax Court
Petitioner was administrator of an estate and employed an attorney to represent the estate in the probate proceedings and tax matters. A few days before petitioner's final accounting was filed and approved by the probate court, the attorney asked petitioner to sign an amended estate tax return reporting additional tax due as a result of after-discovered assets.
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Petitioner was administrator of an estate and employed an attorney to represent the estate in the probate proceedings and tax matters. A few days before petitioner's final accounting was filed and approved by the probate court, the attorney asked petitioner to sign an amended estate tax return reporting additional tax due as a result of after-discovered assets. Petitioner was apparently not told by the attorney to pay the additional tax, and petitioner distributed all of the assets of the estate without paying the additional tax. Held: Under 31 U.S.C. sec. 192, petitioner is personally liable…
1Opinion of the Court
Kenneth Leigh, Petitioner v. Commissioner of Internal Revenue, Respondent
Leigh v. Commissioner
Docket No. 10951-76
United States Tax Court
72 T.C. 1105; 1979 U.S. Tax Ct. LEXIS 58;
September 17, 1979, Filed
Decision will be entered under Rule 155.
Petitioner was administrator of an estate and employed an attorney to represent the estate in the probate proceedings and tax matters. A few days before petitioner's final accounting was filed and approved by the probate court, the attorney asked petitioner to sign an amended estate tax return reporting additional tax due as a result of after-discovered…
2Cases cited21 opinions
- Estate of Frank Duttenhofer, Deceased, Albert J. Uhlenbrock and William Duttenhofer, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- Duttenhofer v. CommissionerUnited States Tax Court · 1967
- King v. United StatesSupreme Court of the United States · 1964
- In Re Fisk's Estate. Fisk v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
- Leuthesser v. CommissionerUnited States Tax Court · 1952
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