Peterson v. Commissioner
United States Tax Court
Rules of Practice -- Proper Party -- Verification of Petition -- Rules 6, 7(a)(2), and 7(c)(4)(D). -- After filing a joint income tax return, the husband died leaving his wife as the sole beneficiary of his estate. A single joint deficiency notice was sent to the husband's estate and to the surviving wife. She timely filed a petition for both which was verified for herself and as surviving spouse for the estate.
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Rules of Practice -- Proper Party -- Verification of Petition -- Rules 6, 7(a)(2), and 7(c)(4)(D). -- After filing a joint income tax return, the husband died leaving his wife as the sole beneficiary of his estate. A single joint deficiency notice was sent to the husband's estate and to the surviving wife. She timely filed a petition for both which was verified for herself and as surviving spouse for the estate. Respondent moved to dismiss for lack of jurisdiction as to the estate because the petition was not filed by a person duly authorized to act for the decedent. Shortly thereafter the…
1Opinion of the Court
Estate of Charles A. Peterson, Deceased, and Georgia R. Peterson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Peterson v. Commissioner
Docket No. 5490-65
United States Tax Court
45 T.C. 497; 1966 U.S. Tax Ct. LEXIS 136;
February 28, 1966, Filed
Rules of Practice -- Proper Party -- Verification of Petition -- Rules 6, 7(a)(2), and 7(c)(4)(D). -- After filing a joint income tax return, the husband died leaving his wife as the sole beneficiary of his estate. A single joint deficiency notice was sent to the husband's estate and to the surviving wife. She timely filed a petition for…
2Cases cited10 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Ansley v. BakerTexas Supreme Court · 1855
- Estate of Arnett v. CommissionerUnited States Tax Court · 1958
- Davison v. CommissionerUnited States Tax Court · 1949
- Estate of Eversole v. CommissionerUnited States Tax Court · 1963
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