Legal Opinion

Krueger v. Commissioner

United States Tax Court

Decided September 14, 1967No. Docket Nos. 2656-64, 2686-64Published

1. Held, stipulated decisions entered by the Tax Court determining deficiencies against two estates are res judicata as to the liabilities of the estates in a later action involving the assessment of such liabilities against the transferees of the estates. 2. Held, an executor or administrator of an estate who files with the Commissioner the notice of fiduciary relationship in accordance with sec. 6903, I.R.C. 1954, but does not file notice that such fiduciary relationship…

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1. Held, stipulated decisions entered by the Tax Court determining deficiencies against two estates are res judicata as to the liabilities of the estates in a later action involving the assessment of such liabilities against the transferees of the estates. 2. Held, an executor or administrator of an estate who files with the Commissioner the notice of fiduciary relationship in accordance with sec. 6903, I.R.C. 1954, but does not file notice that such fiduciary relationship has terminated, has authority to bind such estate by agreeing to stipulated decisions before the Tax Court even though…

1Opinion of the Court

David Krueger, Transferee, Estate of William Krueger, Deceased; Estate of Anna Krueger, Deceased, Petitioner v. Commissioner of Internal Revenue, Respondent; Henry Krueger, Petitioner v. Commissioner of Internal Revenue, Respondent

Krueger v. Commissioner

Docket Nos. 2656-64, 2686-64

United States Tax Court

48 T.C. 824; 1967 U.S. Tax Ct. LEXIS 44;

September 14, 1967, Filed

The parties are directed to move with respect to further proceedings in the case, or otherwise act, on or before Oct. 16, 1967.

1. Held, stipulated decisions entered by the Tax Court determining deficiencies against two estates…

2Cases cited28 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Cromwell v. County of SacSupreme Court of the United States · 1877
  3. Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
  4. Mercoid Corp. v. Mid-Continent Investment Co.Supreme Court of the United States · 1944
  5. Russell v. PlaceSupreme Court of the United States · 1877

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