Legal Opinion

Estate of Di Rezza v. Commissioner

United States Tax Court

Decided January 11, 1982No. Docket No. 16705-79Published

P delinquently filed an estate tax return. Accordingly, respondent summarily assessed additions to tax for late filing and late payment. Respondent subsequently examined P's return and proposed an additional estate tax liability and an addition to tax for late filing in respect of that liability. P agreed to the additional tax liability and paid it. However, the addition to tax was disputed.

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P delinquently filed an estate tax return. Accordingly, respondent summarily assessed additions to tax for late filing and late payment. Respondent subsequently examined P's return and proposed an additional estate tax liability and an addition to tax for late filing in respect of that liability. P agreed to the additional tax liability and paid it. However, the addition to tax was disputed. Respondent then sent a statutory notice determining the disputed addition but no deficiency in estate tax. Held, this Court has jurisdiction to redetermine the disputed addition for late filing because it…

1Opinion of the Court

Estate of Nero DiRezza, Deceased, James L. DiRezza, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Di Rezza v. Commissioner

Docket No. 16705-79

United States Tax Court

78 T.C. 19; 1982 U.S. Tax Ct. LEXIS 151; 78 T.C. No. 2;

January 11, 1982, Filed

Decision will be entered for the respondent.

P delinquently filed an estate tax return. Accordingly, respondent summarily assessed additions to tax for late filing and late payment. Respondent subsequently examined P's return and proposed an additional estate tax liability and an addition to tax for late…

Also in this document: Concurring in part, dissenting in part.

2Cases cited44 opinions

  1. New York Trust Co. v. EisnerSupreme Court of the United States · 1921
  2. Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
  3. Jackson v. CommissionerUnited States Tax Court · 1979
  4. Estate of Christ v. Comm'rUnited States Tax Court · 1970
  5. Estate of Daisy F. Christ, Deceased, Robert Johnson Christ v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973

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