Estate of Meyer v. Commissioner
United States Tax Court
Following an initial audit of the Federal estate tax return of Ella T. Meyer, petitioner received a document from the district director of internal revenue entitled "Estate Tax Closing Letter" which showed that a net estate tax of $ 68,883.78 had been paid and stated that the letter could be exhibited as evidence that the Federal estate tax liability of the estate had been discharged.
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Following an initial audit of the Federal estate tax return of Ella T. Meyer, petitioner received a document from the district director of internal revenue entitled "Estate Tax Closing Letter" which showed that a net estate tax of $ 68,883.78 had been paid and stated that the letter could be exhibited as evidence that the Federal estate tax liability of the estate had been discharged. Held: The letter did not constitute a final closing agreement under sec. 7121, I.R.C. 1954. It also does not estop the Commissioner from making a timely determination of a deficiency in estate tax based upon an…
1Opinion of the Court
Estate of Ella T. Meyer, East Wisconsin Trustee Company, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Meyer v. Commissioner
Docket No. 2860-71
United States Tax Court
58 T.C. 69; 1972 U.S. Tax Ct. LEXIS 147;
April 17, 1972, Filed
Following an initial audit of the Federal estate tax return of Ella T. Meyer, petitioner received a document from the district director of internal revenue entitled "Estate Tax Closing Letter" which showed that a net estate tax of $ 68,883.78 had been paid and stated that the letter could be exhibited as evidence that the Federal estate…
2Cases cited29 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
- Burnet v. PorterSupreme Court of the United States · 1931
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