Groetzinger v. Commissioner
United States Tax Court
Petitioners are transferees of the assets of an estate. The estate had timely filed its Federal estate tax return and, after certain adjustments, paid its estate tax together with all deficiencies. Subsequently, respondent refunded the bulk of those taxes. The refund was made without the taxpayer estate's request for it but because respondent erroneously posted the estate's payments of its taxes.
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Petitioners are transferees of the assets of an estate. The estate had timely filed its Federal estate tax return and, after certain adjustments, paid its estate tax together with all deficiencies. Subsequently, respondent refunded the bulk of those taxes. The refund was made without the taxpayer estate's request for it but because respondent erroneously posted the estate's payments of its taxes. Respondent determined the liabilities of petitioners as transferees in the amounts transferred to them. Held, the refund was not a rebate within the meaning of sec. 6211(b)(2), but was an…
1Opinion of the Court
Walker Groetzinger, Petitioner v. Commissioner of Internal Revenue, Respondent; Sara H. Groezinger, Petitioner v. Commissioner of Internal Revenue, Respondent
Groetzinger v. Commissioner
Docket Nos. 5446-76, 5447-76
United States Tax Court
69 T.C. 309; 1977 U.S. Tax Ct. LEXIS 20;
November 28, 1977, Filed
Decisions will be entered for the respondent.
Petitioners are transferees of the assets of an estate. The estate had timely filed its Federal estate tax return and, after certain adjustments, paid its estate tax together with all deficiencies. Subsequently, respondent refunded the bulk of those…
2Cases cited14 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. SternSupreme Court of the United States · 1958
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
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