Parker v. Commissioner
United States Board of Tax Appeals
1. The executors of the estate filed their return on December 15, 1925. The Commissioner determined a deficiency and on July 5, 1927, mailed a notice of deficiency to the executors. On August 22, 1927, the trustees of the estate, being the same persons as the executors, filed an appeal with this Board, which the Board dismissed on October 20, 1930, for want of jurisdiction. On February 16, 1931, the Commissioner mailed a deficiency notice to the petitioners as transferees.
Read the full summary
1. The executors of the estate filed their return on December 15, 1925. The Commissioner determined a deficiency and on July 5, 1927, mailed a notice of deficiency to the executors. On August 22, 1927, the trustees of the estate, being the same persons as the executors, filed an appeal with this Board, which the Board dismissed on October 20, 1930, for want of jurisdiction. On February 16, 1931, the Commissioner mailed a deficiency notice to the petitioners as transferees. The petition in this proceeding was filed by the petitioners as transferees on March 2, 1931. Held, that under section…
1Opinion of the Court
*347OPINION.
Matthews :
In the stipulation of facts filed by the parties to this proceeding it is agreed that if there is any deficiency in estate tax *348due from the estate of Herbert L. Parker not barred by the statute of limitations, the petitioners, who were appointed trustees of the estate under the decedent’s will, are liable for the tax as transferees under section 316 of the Revenue Act of 1926. We shall first consider the question whether the proposed deficiency is barred by the statute of limitations.
The decedent died on December 15, 1924, and the estate tax return was filed on December 15,…
2Cases cited10 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Central Bank of Washington v. HumeSupreme Court of the United States · 1888
- Cyrus H. McCormick v. David BurnetSupreme Court of the United States · 1931
5 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Eversole v. CommissionerUnited States Tax Court · 1966
- Helvering v. ParkerCourt of Appeals for the Eighth Circuit · 1936
- Golden v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- United States v. BarberDistrict Court, D. Maryland · 1938
- Cain v. CommissionerUnited States Board of Tax Appeals · 1941
6 more not listed; retrieve them via the Exa API.