Baptiste v. Commissioner
United States Tax Court
In previous opinions it was determined that each petitioner was personally liable for unpaid estate tax to the extent of the value, at the time of decedent's death, of each petitioner's interest in the proceeds of insurance on decedent's life.
Read the full summary
In previous opinions it was determined that each petitioner was personally liable for unpaid estate tax to the extent of the value, at the time of decedent's death, of each petitioner's interest in the proceeds of insurance on decedent's life. Held: (1) Each petitioner is liable for interest under Federal law on the amount of his personal liability for unpaid estate tax from the due date of the transferor's estate tax return; and (2) the limitation imposed by sec. 6324(a)(2) does not apply to petitioners' respective liabilities for such interest.
1Opinion of the Court
GABRIEL J. BAPTISTE, JR., TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; RICHARD M. BAPTISTE, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Baptiste v. Commissioner
Docket Nos. 383-90, 384-901
United States Tax Court
100 T.C. 252; 1993 U.S. Tax Ct. LEXIS 16; 100 T.C. No. 16;
March 29, 1993, Filed
In previous opinions it was determined that each petitioner was personally liable for unpaid estate tax to the extent of the value, at the time of decedent's death, of each petitioner's interest in the proceeds of insurance on decedent's life. Held: (1)…
Also in this document: Concurrence · Ruwe; Concurrence · Halpern; Dissent.
2Cases cited11 opinions
- Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
- Stein v. CommissionerUnited States Tax Court · 1962
- Lowy v. CommissionerUnited States Tax Court · 1960
6 more not listed; retrieve them via the Exa API.