Estate of Lombard v. Commissioner
United States Tax Court
On Feb. 27, 1975, duplicate original notices of deficiency were mailed to the estate of decedent, a United States citizen domiciled in Panama where over 75 percent of her assets were located. One of the notices was addressed to the executor under decedent's will, which was probated in Panama, and the other to an administrator in Connecticut, where the rest of decedent's assets were located.
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On Feb. 27, 1975, duplicate original notices of deficiency were mailed to the estate of decedent, a United States citizen domiciled in Panama where over 75 percent of her assets were located. One of the notices was addressed to the executor under decedent's will, which was probated in Panama, and the other to an administrator in Connecticut, where the rest of decedent's assets were located. On July 24, 1975, the Connecticut administrator transmitted the estate's petition to this Court by certified mail. Held, under sec. 6213(a), I.R.C. 1954, decedent's estate had 150 days within which to file…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent has filed a motion to dismiss for lack of jurisdiction. The issue is whether the petition was timely filed. The answer depends upon whether, under section 6213(a),1 petitioner had 90 or 150 days after the notice of deficiency was mailed to file a petition with this Court for a redetermination of the deficiency.
Decedent Bessie Deming Lombard died on March 12,1971. At the time of her death, she was a United States citizen domiciled in Panama. Her estate included assets located in Panama and in the Unitéd States. Of the assets reported on decedent’s Federal…
2Cases cited7 opinions
- Commissioner of Internal Revenue v. New York Trust Co.Court of Appeals for the Second Circuit · 1931
- Estate of Krueger v. CommissionerUnited States Tax Court · 1960
- Mindell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Hamilton v. CommissionerUnited States Tax Court · 1949
- Cowan v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Looper v. CommissionerUnited States Tax Court · 1980
- Lewy v. CommissionerUnited States Tax Court · 1977
- Ferre v. CommissionerUnited States Tax Court · 1982
- Estate of Lombard v. CommissionerUnited States Tax Court · 1976
- Lawton v. CommissionerUnited States Tax Court · 1979
2 more not listed; retrieve them via the Exa API.