Du Puy v. Commissioner
United States Tax Court
On Dec. 1, 1966, respondent issued a notice of deficiency to the estate of Charles M. DuPuy and the executors thereof determining a deficiency in the estate tax liability of the estate. On the same date respondent issued separate notices of deficiency to each of the executors determining that each was personally liable as a fiduciary, under sec. 3467 of the Revised Statutes, for the estate tax due from the estate.
Read the full summary
On Dec. 1, 1966, respondent issued a notice of deficiency to the estate of Charles M. DuPuy and the executors thereof determining a deficiency in the estate tax liability of the estate. On the same date respondent issued separate notices of deficiency to each of the executors determining that each was personally liable as a fiduciary, under sec. 3467 of the Revised Statutes, for the estate tax due from the estate. A timely petition was filed with this Court in the name of the estate and the executors in their representative capacities seeking a redetermination of the estate tax liability of…
1Opinion of the Court
OPINION
Dkennen, Judge:
On December 1, 1966, respondent issued a notice of deficiency to the “Estate of Charles M. DuPuy, The Putnam Trust Company of Greenwich, Co-executor, Jessie Cook Lauder (DuPuy), Co-executrix, Herbert DuPuy Merrick, Co-executor,” determining a deficiency in the estate tax liability for the Estate of Charles M. DuPuy in the amount of $473,078.27. On the same date respondent also issued separate notices of deficiency to each of the coexecutors named above, addressed to them as indicated by the following example, i.e., “Herbert DuPuy Merrick, Co-executor,” on each of which…
2Cases cited4 opinions
- Safe Deposit & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Michael v. CommissionerUnited States Board of Tax Appeals · 1931
- Powers v. CommissionerUnited States Board of Tax Appeals · 1930
- Shea v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by12 opinions
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- Estate of Meyer v. CommissionerUnited States Tax Court · 1972
- O'Neil v. CommissionerUnited States Tax Court · 1976
- Martin v. CommissionerCourt of Appeals for the Tenth Circuit · 2006
- Martin v. Comm'rUnited States Tax Court · 2004
7 more not listed; retrieve them via the Exa API.