Estate of Giovacchini v. Comm'r
United States Tax Court
R determined a deficiency in E's Federal estate tax. In a separate notice of deficiency, R determined a Federal gift tax deficiency for D's 2000 tax year. Both deficiencies inter alia were determined on the basis of a determined understatement of the value of High Meadows, parcels of real property covering approximately 2,500 acres near Lake Tahoe, California. R also determined accuracy-related penalties pursuant to I.R.C. sec. 6662 with respect to both deficiencies.
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R determined a deficiency in E's Federal estate tax. In a separate notice of deficiency, R determined a Federal gift tax deficiency for D's 2000 tax year. Both deficiencies inter alia were determined on the basis of a determined understatement of the value of High Meadows, parcels of real property covering approximately 2,500 acres near Lake Tahoe, California. R also determined accuracy-related penalties pursuant to I.R.C. sec. 6662 with respect to both deficiencies. After concessions, the issues before the Court are the values for estate and gift tax purposes of D's interest in High Meadows…
1Opinion of the Court
ESTATE OF SHIRLEY C. GIOVACCHINI, DECEASED, DONOR, LISA LEKUMBERRY, EXECUTOR AND TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Giovacchini v. Comm'r
Docket No. 20122-05
United States Tax Court
T.C. Memo 2013-27; 2013 Tax Ct. Memo LEXIS 29; 105 T.C.M. (CCH) 1179;
January 24, 2013, Filed
Decision will be entered under Rule 155.
R determined a deficiency in E's Federal estate tax. In a separate notice of deficiency, R determined a Federal gift tax deficiency for D's 2000 tax year. Both deficiencies inter alia were determined on the basis of a determined understatement of…
2Cases cited60 opinions
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- Welch v. HelveringSupreme Court of the United States · 1933
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
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