Legal Opinion
Estate of Frank Branson, Deceased Mary M. March v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 5, 2001No. 00-70293PublishedCited by 46 opinions
1Opinion of the Court
SNEED, Circuit Judge:
This case is before us on appeal from a judgment of the Tax Court. In the proceeding below, the Tax Court held that Appellee, the Estate of Frank Branson, had underpaid its estate taxes and owed a deficiency of $348,016. The Tax Court further held that Appellee need not pay the full amount of the deficiency. Rather, the Estate could, under, the doctrine of equitable recoupment, credit a $96,515 income tax overpayment against the estate tax deficiency and pay only the remainder.
The Commissioner of Internal Revenue (“Commissioner”) appeals the Tax Court’s application of…
2Cases cited37 opinions
- Kokkonen v. Guardian Life Insurance Co. of AmericaSupreme Court of the United States · 1994
- Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Bull v. United StatesSupreme Court of the United States · 1935
- United States v. DalmSupreme Court of the United States · 1990
32 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Charlotte's Office Boutique, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
- Commissioner of Internal Revenue v. Gwendolyn A. Ewing, Gwendolyn A. Ewing v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Adkison v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Conrad Gorospe Shirley Gorospe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
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