Legal Opinion

Baptiste v. Commissioner

United States Tax Court

Decided March 29, 1993No. Docket Nos. 383-90, 384-90Published

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.

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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

  1. Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
  2. Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
  3. Schuster v. CommissionerUnited States Tax Court · 1959
  4. Stein v. CommissionerUnited States Tax Court · 1962
  5. Lowy v. CommissionerUnited States Tax Court · 1960

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