Estate of Koss v. Commissioner
United States Tax Court
P's Federal estate tax return reported a $ 100,000 deduction for an estimated personal representative fee and a $ 125,000 deduction for an estimated selling expense that purportedly would be paid on the prospective sale of certain real estate included in D's gross estate. R determined that these deductions should have been reported as $ 26,400 and zero, respectively. Held: P may deduct $26,400 for an estimated personal representative fee.
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P's Federal estate tax return reported a $ 100,000 deduction for an estimated personal representative fee and a $ 125,000 deduction for an estimated selling expense that purportedly would be paid on the prospective sale of certain real estate included in D's gross estate. R determined that these deductions should have been reported as $ 26,400 and zero, respectively. Held: P may deduct $26,400 for an estimated personal representative fee. Held, further, P may not deduct any estimated selling expense for the prospective sale of the real estate.
1Opinion of the Court
ESTATE OF GERTRUDE F. KOSS, DECEASED, ELAINE SAXEN, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Koss v. Commissioner
Docket No. 27337-92
United States Tax Court
T.C. Memo 1994-599; 1994 Tax Ct. Memo LEXIS 610; 68 T.C.M. (CCH) 1356;
December 7, 1994, Filed
Decision will be entered for respondent.
P's Federal estate tax return reported a $ 100,000 deduction for an estimated personal representative fee and a $ 125,000 deduction for an estimated selling expense that purportedly would be paid on the prospective sale of certain real estate included in D's…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Florida Patient's Compensation Fund v. RoweSupreme Court of Florida · 1985
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
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