Powell v. Commissioner

HOLLOWAY, Circuit Judge.

In this appeal, a taxpayer seeks the reversal of the Tax Court Judge’s post-trial decision to adopt the Commissioner of Internal Revenue’s computation of the taxpayer’s estate tax deficiency rather than the taxpayer’s own computation.

In late 2001, the Internal Revenue Service issued estate and gift tax notices of deficiency to the Estate of Silvia Gore, and the Estate soon filed petitions in the United States Tax Court challenging both deficiencies. Following the issuance of her post-trial opinion, the Tax Court Judge permitted both parties to submit computations of…