Legal Opinion
Estate of Paul Mitchell, Deceased, Patrick T. Fujieki v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 25, 2001No. 99-70421PublishedCited by 15 opinions
1Opinion of the Court
WARD LAW, Circuit Judge:
The Estate of Paul Mitchell (the “Estate”) petitions for review of the United States Tax Court’s decision allowing the Commissioner of the Internal Revenue Service (the “Commissioner”) to assess an additional $2,404,571 in federal estate taxes. The Estate claims that the Tax Court erred by: (1) finding that the Commissioner timely notified the Estate of the additional taxes due; (2) failing to shift the burden of proof to the Commissioner and failing to require the government to justify its calculation of the additional taxes; (3) failing to provide a detailed…
2Cases cited16 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Brian Miller v. United StatesCourt of Appeals for the Sixth Circuit · 1986
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Lesly Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
11 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
- Estate of Trompeter v. CommissionerCourt of Appeals for the Ninth Circuit · 2002
- Chapman Glen Ltd. v. CommissionerUnited States Tax Court · 2013
- Cavallaro v. CommissionerCourt of Appeals for the First Circuit · 2016
- Shea Homes, Inc. v. CommissionerUnited States Tax Court · 2014
10 more not listed; retrieve them via the Exa API.