Greenoak Holdings Ltd. v. Comm'r
United States Tax Court
R issued a final notice of intent to levy to estate (E) to collect unpaid estate tax. E requested a hearing before an IRS Appeals officer (AO) pursuant to I.R.C. sec. 6330. Following the hearing, AO issued a notice of determination to E sustaining the proposed levy as to E's nonprobate assets.
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R issued a final notice of intent to levy to estate (E) to collect unpaid estate tax. E requested a hearing before an IRS Appeals officer (AO) pursuant to I.R.C. sec. 6330. Following the hearing, AO issued a notice of determination to E sustaining the proposed levy as to E's nonprobate assets. Among the nonprobate assets reported on the estate tax return was an offshore trust that owned certain entities (Ps). Ps petitioned the Tax Court for review of the notice of determination issued to E. No petition was filed on behalf of E. R moved to dismiss for lack of jurisdiction. Held: The "person"…
1Opinion of the Court
GREENOAK HOLDINGS LIMITED, SOUTHBROOK PROPERTIES LIMITED AND WESTLYN PROPERTIES LIMITED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Greenoak Holdings Ltd. v. Comm'r
Docket No. 12075-13L.
United States Tax Court
143 T.C. 170; 2014 U.S. Tax Ct. LEXIS 39; 143 T.C. No. 8;
September 16, 2014, Filed
An order of dismissal for lack of jurisdiction will be entered.
R issued a final notice of intent to levy to estate (E) to collect unpaid estate tax. E requested a hearing before an IRS Appeals officer (AO) pursuant to I.R.C. sec. 6330. Following the hearing, AO issued a notice of…
2Cases cited16 opinions
- K Mart Corp. v. Cartier, Inc.Supreme Court of the United States · 1988
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
- Murphy v. Comm'rUnited States Tax Court · 2005
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