Estate of Sower v. Comm'r
United States Tax Court
H died in 2012, and H's estate reported a deceased spousal unused exclusion (DSUE) and elected portability of the DSUE. In 2013 R sent H's estate a letter reporting that the return had been accepted as filed. W died in 2013. W's estate claimed the DSUE reported by H's estate. As a part of an examination of the estate tax return filed by W's estate, R also examined the estate tax return filed by H's estate.
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H died in 2012, and H's estate reported a deceased spousal unused exclusion (DSUE) and elected portability of the DSUE. In 2013 R sent H's estate a letter reporting that the return had been accepted as filed. W died in 2013. W's estate claimed the DSUE reported by H's estate. As a part of an examination of the estate tax return filed by W's estate, R also examined the estate tax return filed by H's estate. R reduced the amount of the DSUE by the amount of taxable gifts given by H but did not determine or assess a deficiency against H's estate. But R determined an estate tax deficiency against…
1Opinion of the Court
ESTATE OF MINNIE LYNN SOWER, DECEASED, FRANK W. SOWER, JR. AND JOHN R. SOWER, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Sower v. Comm'r
Docket No. 32361-15.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 44; 149 T.C. No. 11;
September 11, 2017, Filed
Decision will be entered for respondent.
H died in 2012, and H's estate reported a deceased spousal unused exclusion (DSUE) and elected portability of the DSUE. In 2013 R sent H's estate a letter reporting that the return had been accepted as filed. W died in 2013. W's estate claimed the DSUE reported by H's…
2Cases cited18 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Swain v. Comm'rUnited States Tax Court · 2002
- Burnet v. PorterSupreme Court of the United States · 1931
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