Pert v. Commissioner
United States Tax Court
Kathleen M. Pert signed closing agreements (Forms 866) pursuant to sec. 7121 I.R.C., for tax years 1986, 1988, and 1989 for both herself and as personal representative of the estate of her deceased husband, Timothy C. Riffe. Respondent accepted the closing agreements. Timothy Riffe and Kathleen Pert filed joint returns for those years. Under the closing agreements, Timothy Riffe, deceased, is liable for the addition to tax for fraud for 1986 and Kathleen Pert is not.
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Kathleen M. Pert signed closing agreements (Forms 866) pursuant to sec. 7121 I.R.C., for tax years 1986, 1988, and 1989 for both herself and as personal representative of the estate of her deceased husband, Timothy C. Riffe. Respondent accepted the closing agreements. Timothy Riffe and Kathleen Pert filed joint returns for those years. Under the closing agreements, Timothy Riffe, deceased, is liable for the addition to tax for fraud for 1986 and Kathleen Pert is not. Kathleen Pert signed a settlement stipulation for 1987 on her own behalf and as personal representative of the Estate of…
1Opinion of the Court
HARVEY M. PERT, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent KATHLEEN M. PERT, F.K.A. KATHLEEN M. RIFFE, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pert v. Commissioner
Docket Nos. 13783-94, 13784-94.
United States Tax Court
105 T.C. 370; 1995 U.S. Tax Ct. LEXIS 60; 105 T.C. No. 24;
November 15, 1995, Filed
Orders will be issued granting respondent's motions for partial summary judgment.
Kathleen M. Pert signed closing agreements (Forms 866) pursuant to sec. 7121 I.R.C., for tax years 1986, 1988, and 1989 for both herself and as personal…
2Cases cited34 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Naftel v. CommissionerUnited States Tax Court · 1985
- Weinberger v. Hynson, Westcott & Dunning, Inc.Supreme Court of the United States · 1973
- United States v. International Building Co.Supreme Court of the United States · 1953
- Espinoza v. CommissionerUnited States Tax Court · 1982
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