Commissioner of Revenue Services v. Estate of Sulouff

In the administration of Connecticut’s succession tax, it is the responsibility of the fiduciary or transferee of an estate to file a return “containing all items necessary to the correct computation and assessment of the tax.” General Statutes § 12-359 (a). The commissioner of revenue services (commissioner) has 120 days from his receipt of the return to file “such objections as he may have to the valuations or concessions of taxability appearing thereon.” General Statutes § 12-359 (b). The question presented in this case is whether the commissioner’s objections to expenses paid by the…