Crawford v. Commissioner
United States Tax Court
Pursuant to a jeopardy assessment of deficiencies in the individual income taxes of the residuary legatee-executor of decedent's estate, respondent served notices of levy upon certain third parties during the time the estate was in administration for property belonging to the residuary legatee-executor as beneficiary of the estate.
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Pursuant to a jeopardy assessment of deficiencies in the individual income taxes of the residuary legatee-executor of decedent's estate, respondent served notices of levy upon certain third parties during the time the estate was in administration for property belonging to the residuary legatee-executor as beneficiary of the estate. Prior to the issuance of the notice of deficiency herein, respondent received from the parties upon whom such levies had been served, cash and other assets belonging to the estate in amounts more than sufficient to satisfy the entire tax liability of the estate…
1Opinion of the Court
BRUCE, Judge:
Respondent determined a deficiency in the estate tax of the petitioner in the amount of $5,247.03. The sole issue is whether the Court has jurisdiction to redetermine the deficiency. The parties have stipulated that if the Court has jurisdiction, the amount of the deficiency in petitioner’s tax is $2,655.04.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulated facts and the exhibits attached to the stipulation are incorporated by this reference.
Mary Hart Crawford (hereinafter referred to as the decedent) died testate on November 18, 1958, a resident of…
2Cases cited18 opinions
- United States v. BessSupreme Court of the United States · 1958
- United States v. First National City BankSupreme Court of the United States · 1965
- United States v. Cornelius W. SullivanCourt of Appeals for the Third Circuit · 1964
- Raffaele v. Granger, Collector of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Walsh v. Comm'rUnited States Tax Court · 1954
13 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- In re OrmistonUnited States Bankruptcy Court, E.D. North Carolina · 2013
- Hillenbrand v. Comm'rUnited States Tax Court · 2002
- Craig v. United StatesDistrict Court, S.D. Texas · 1999
- Crawford v. CommissionerUnited States Tax Court · 1966
- Joseph D. and Wanda S. Lunsford v. CommissionerUnited States Tax Court · 2001
4 more not listed; retrieve them via the Exa API.