Estate of Egger v. Commissioner
United States Tax Court
This case is on remand from the Court of Appeals for consideration by this Court of whether the decision should be vacated to allow additional deductions for expenses of administration. The issue was not raised prior to the entry of the decision, and petitioner did not move to vacate that decision. Held, under the circumstances, the decision will be vacated.
1Opinion of the Court
SUPPLEMENTAL OPINION
Chabot, Judge:
This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d) of the Code (redesignated section 7443A(b)) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Powell, Special Trial Judge:
This case is before the Court on petitioner’s motion to vacate in which petitioner prays that the…
2Cases cited9 opinions
- United States v. Wells Fargo BankSupreme Court of the United States · 1988
- Senate Realty Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
- Koufman v. CommissionerUnited States Tax Court · 1977
- Estate of Fawcett v. CommissionerUnited States Tax Court · 1975
- Moir v. United StatesCourt of Appeals for the First Circuit · 1945
4 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Stewart v. Comm'rUnited States Tax Court · 2006
- Cowan v. Comm'rUnited States Tax Court · 2006
- Estate of Egger v. CommissionerUnited States Tax Court · 1989
- Estate of Street v. CommissionerUnited States Tax Court · 1994
- Hoffman v. Comm'rUnited States Tax Court · 2006
7 more not listed; retrieve them via the Exa API.