Estate of Galloway v. Commissioner
United States Tax Court
R sent a statutory notice to decedent and decedent's spouse determining a deficiency in income tax. No State proceeding for administration of decedent's will had been commenced or was necessary. A, one of decedent's three children by a former spouse and a 25-percent beneficiary of decedent's estate, filed a petition contesting R's determination. Held: 1. The Court appoints A as special administrator of decedent's estate to conduct this litigation, pursuant to Cal. Civ. Proc.
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R sent a statutory notice to decedent and decedent's spouse determining a deficiency in income tax. No State proceeding for administration of decedent's will had been commenced or was necessary. A, one of decedent's three children by a former spouse and a 25-percent beneficiary of decedent's estate, filed a petition contesting R's determination. Held: 1. The Court appoints A as special administrator of decedent's estate to conduct this litigation, pursuant to Cal. Civ. Proc. Code sec. 377.33 (West Supp. 1994). 2. A is a proper party to conduct this litigation under Rule 60(c), Tax Court Rules…
1Opinion of the Court
Estate of Robert B. Galloway, Deceased, Christine Armijo, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Galloway v. Commissioner
Docket No. 1176-94
United States Tax Court
103 T.C. 700; 1994 U.S. Tax Ct. LEXIS 82; 103 T.C. No. 38;
November 21, 1994, Filed
An appropriate order will be issued and a decision for petitioner will be entered.
R sent a statutory notice to decedent and decedent's spouse determining a deficiency in income tax. No State proceeding for administration of decedent's will had been commenced or was necessary. A, one of decedent's three children by…
2Cases cited3 opinions
- Mosells Silvey Pitner v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Eiges v. CommissionerUnited States Tax Court · 1993
- Estate of Galloway v. CommissionerUnited States Tax Court · 1994