Estate of Bell v. Commissioner
United States Tax Court
Ps elected, under sec. 6166, I.R.C. 1954, to pay a portion of their respective Federal estate tax liabilities on the installment basis. Ps erred in valuing the property with respect to which estate taxes were being paid on the installment basis, and thereby erred in determining their schedules of payment required by sec. 6166. By reason of such errors, the installment payments each P made exceeded the installment payments which properly should have been made by each.
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Ps elected, under sec. 6166, I.R.C. 1954, to pay a portion of their respective Federal estate tax liabilities on the installment basis. Ps erred in valuing the property with respect to which estate taxes were being paid on the installment basis, and thereby erred in determining their schedules of payment required by sec. 6166. By reason of such errors, the installment payments each P made exceeded the installment payments which properly should have been made by each. Also by reason of such errors, the total amount each P has paid exceeds their respective total Federal estate tax liabilities.…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined a deficiency in Federal estate taxes for the Estate of Laura V. Larsen Bell in the amount of $1,143,839, and for the Estate of Charles C. Bell in the amount of $1,130,668.
These cases were consolidated for briefing and opinion and were submitted fully stipulated pursuant to Rule 122.1 The stipulated facts and the exhibits attached thereto are incorporated herein by reference. After concessions,2 the issue for decision is the amount by which each petitioner has overpaid its respective estate taxes and interest.
Laura V. Larsen Bell and Charles C. Bell…
2Cases cited13 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Flora v. United StatesSupreme Court of the United States · 1958
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
8 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Estate of Roski v. Comm'rUnited States Tax Court · 2007
- Estate of Benjamin Shapiro, Deceased, Saul A. Shapiro, and Stephen Shapiro v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1997
- Sunoco, Inc. v. Comm'rUnited States Tax Court · 2004
- Estate of Adell v. Comm'rUnited States Tax Court · 2014
- Estate of Adell v. Comm'rUnited States Tax Court · 2013
9 more not listed; retrieve them via the Exa API.