Estate of Rothpletz v. Commissioner
United States Tax Court
Held, Real property owned by a decedent who died in 1980 failed to qualify for special use valuation under sec. 2032A, I.R.C. 1954, because the estate tax return in which the election was made was not timely filed. Held further, reliance upon an attorney to prepare and file the estate tax return does not constitute reasonable cause for failure to timely file the return within the meaning of sec. 6651(a)(1), I.R.C. 1954.
1Opinion of the Court
ESTATE OF HANS E. ROTHPLETZ, DECEASED, MICHAEL E. ROTHPLETZ, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Rothpletz v. Commissioner
Docket No. 38934-84.
United States Tax Court
T.C. Memo 1987-310; 1987 Tax Ct. Memo LEXIS 310; 53 T.C.M. (CCH) 1214; T.C.M. (RIA) 87310;
June 24, 1987.
Held, Real property owned by a decedent who died in 1980 failed to qualify for special use valuation under sec. 2032A, I.R.C. 1954, because the estate tax return in which the election was made was not timely filed. Held further, reliance upon an attorney to prepare and file the estate…
2Cases cited11 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Brian Miller v. United StatesCourt of Appeals for the Sixth Circuit · 1986
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
- Estate of Cowser v. CommissionerUnited States Tax Court · 1983
6 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
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