Illinois Masonic Home v. Commissioner
United States Tax Court
An estate tax closing letter was mailed to the estate of Clara M. Evans indicating a final total Federal estate tax liability of $ 877,507.45. Pursuant to the terms of the will and after the period of limitations on assessment of additional estate tax against the estate expired, the executor distributed the assets of the estate to petitioners. The Commissioner subsequently determined an additional liability for estate tax.
Read the full summary
An estate tax closing letter was mailed to the estate of Clara M. Evans indicating a final total Federal estate tax liability of $ 877,507.45. Pursuant to the terms of the will and after the period of limitations on assessment of additional estate tax against the estate expired, the executor distributed the assets of the estate to petitioners. The Commissioner subsequently determined an additional liability for estate tax. The distribution of assets represents the transfers which the Commissioner has determined as giving rise to transferee liability. Held, the expiration of the period of…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined that petitioners are hable as transferees as follows for a deficiency in estate tax of the estate of Clara M. Evans:
Petitioner Liability
Illinois Masonic Home. $131,398
Jeffrey T. Bryant. 43,668
Steven T. Bryant . 43,668
Jeanine Gill (Koch) Shryock. 15,439
David T. Bryant. 131,006
Matthew T. Bryant. 43,668
LaVeta Gill. 131,398
Janet Gill Newell. 15,439
Harold Tuttle. 131,398
Pauline Tuttle. 131,398
Donna Kennedy. 131,398
Dianna Lynn Kennedy Schmitt. 22,464
Kathryn Sue Gaskins.i. 22,464
Mark Edward Kennedy. 22,464
Julia Gill Koch. 15,439
Clifford S. Gill. 131,398
Timothy…
2Cases cited7 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Mysse v. CommissionerUnited States Tax Court · 1972
- Schwager v. CommissionerUnited States Tax Court · 1975
- Phyllis Berliant, Transferee v. Commissioner of Internal Revenue, Florence Kraft, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
- Dillman v. CommissionerUnited States Tax Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Hoffman v. Comm'rUnited States Tax Court · 2002
- Richard H. Fendell and Elizabeth A. Fendell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
- Hoffman v. Comm'rUnited States Tax Court · 2002
- Illinois Masonic Home v. CommissionerUnited States Tax Court · 1989
- Lardas v. CommissionerUnited States Tax Court · 1992
3 more not listed; retrieve them via the Exa API.