Legal Opinion

Gabriel J. Baptiste, Jr., Transferee v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided July 12, 1994No. 93-2960PublishedCited by 29 opinions

1Opinion of the Court

McMILLIAN, Circuit Judge.

Gabriel J. Baptiste, Jr. (Gabriel) appeals the United States Tax Court’s determination that (1) the decision in Estate of Baptiste v. Comm’r, No. 44928-85 (T.C. May 13, 1988) {Estate of Baptiste), was res judicata as to the existence and amount of estate tax imposed on the transfer of Gabriel J. Baptiste, Sr.’s Estate for purposes of determining Gabriel’s transferee liability pursuant to 26 U.S.C. § 6324(a), and (2) he was liable for interest on the amount of his personal liability for unpaid estate tax, beyond the value of the property transferred, accrued since the…

2Cases cited8 opinions

  1. Federated Department Stores, Inc. v. MoitieSupreme Court of the United States · 1981
  2. United States v. International Building Co.Supreme Court of the United States · 1953
  3. Headley v. BaconCourt of Appeals for the Eighth Circuit · 1987
  4. Krueger v. CommissionerUnited States Tax Court · 1967
  5. Estate of Willard E. Robertson, Deceased, Walter G. Miller, Successor-Executor v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994

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3Cited by29 opinions

  1. United States of America, Appellant/cross-Appellee v. Lauree Flaa Brekke James Stanley Brekke, Appellees/cross-AppellantsCourt of Appeals for the Eighth Circuit · 1996
  2. United States v. Birnie Davenport, Gordon E. DavenportCourt of Appeals for the Fifth Circuit · 2007
  3. Larken, Inc. v. Dirk Wray, - Appellant., Al YipCourt of Appeals for the Eighth Circuit · 1999
  4. United States v. Finley HilliardCourt of Appeals for the Fifth Circuit · 2015
  5. Schussel v. WerfelCourt of Appeals for the First Circuit · 2014

24 more not listed; retrieve them via the Exa API.

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