Legal Opinion
Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided October 10, 1990No. 89-2366PublishedCited by 108 opinions
1Opinion of the Court
BEAM, Circuit Judge.
The Commissioner of Internal Revenue appeals from a judgment entered by the United States Tax Court in favor of the estate of Leonard A. Wood. The Commissioner had assessed a deficiency of $38,-636.54 in the estate’s 1981 federal estate tax payment due to an untimely election of special use valuation. See 26 U.S.C. § 2032A (1988). The tax court, however, found that the election was timely because of the “timely mailing as timely filing” provision of the Internal Revenue Code. See 26 U.S.C. § 7502 (1988).1 We affirm.
I. BACKGROUND
Leonard A. Wood died a resident of Ea-ston,…
2Cases cited17 opinions
- Midlantic National Bank v. New Jersey Department of Environmental ProtectionSupreme Court of the United States · 1986
- Johnson v. First National Bank Of MontevideoCourt of Appeals for the First Circuit · 1983
- Brian Miller v. United StatesCourt of Appeals for the Sixth Circuit · 1986
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Sylvan v. CommissionerUnited States Tax Court · 1975
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3Cited by108 opinions
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- Lisa Lupyan v. Corinthian Colleges IncCourt of Appeals for the Third Circuit · 2014
- Lois Anderson v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- United States v. Carl Harold MyersCourt of Appeals for the Eleventh Circuit · 1992
- Robinette v. Comm'rUnited States Tax Court · 2004
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