Legal Opinion

Estate of Siegel v. Commissioner

United States Tax Court

Decided March 30, 1977No. Docket No. 1685-76Published

Rules 61 and 63, Tax Court Rules of Practice and Procedure. -- Held, a beneficiary of an estate to whom no notice of deficiency or of transferee liability has been sent cannot properly be joined as a party under Rule 61 or substituted as a party under Rule 63, even though respondent after determining a deficiency in estate tax made a jeopardy assessment and levied on property which respondent contends is properly part of the estate and which each beneficiary seeking to be…

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Rules 61 and 63, Tax Court Rules of Practice and Procedure. -- Held, a beneficiary of an estate to whom no notice of deficiency or of transferee liability has been sent cannot properly be joined as a party under Rule 61 or substituted as a party under Rule 63, even though respondent after determining a deficiency in estate tax made a jeopardy assessment and levied on property which respondent contends is properly part of the estate and which each beneficiary seeking to be joined or substituted contends is property owned jointly by the beneficiaries seeking joinder or substitution. Further…

1Opinion of the Court

Estate of Murray J. Siegel, Deceased, Frederick Zissu and Norman Lipshie, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Siegel v. Commissioner

Docket No. 1685-76

United States Tax Court

67 T.C. 1033; 1977 U.S. Tax Ct. LEXIS 129;

March 30, 1977, Filed

Rules 61 and 63, Tax Court Rules of Practice and Procedure. -- Held, a beneficiary of an estate to whom no notice of deficiency or of transferee liability has been sent cannot properly be joined as a party under Rule 61 or substituted as a party under Rule 63, even though respondent after determining a deficiency in…

2Cases cited14 opinions

  1. Peterson v. United StatesDistrict Court, D. Minnesota · 1966
  2. Commissioner of Internal Revenue v. Revere Land Co.Court of Appeals for the Third Circuit · 1948
  3. Tarver v. CommissionerUnited States Tax Court · 1956
  4. Estate of Theodore Geddings Tarver, Deceased, the Citizens and Southern National Bank of South Carolina v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
  5. Cincinnati Transit, Inc. v. CommissionerUnited States Tax Court · 1971

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