Greenoak Holdings Limited, Southbrook Properties Limited and Westlyn Properties Limited v. Commissioner

143 T.C. No. 8

UNITED STATES TAX COURT GREENOAK HOLDINGS LIMITED, SOUTHBROOK PROPERTIES LIMITED AND WESTLYN PROPERTIES LIMITED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12075-13L. Filed September 16, 2014. R issued a final notice of intent to levy to estate (E) to collect unpaid estate tax. E requested a hearing before an IRS Appeals officer (AO) pursuant to I.R.C. sec. 6330. Following the hearing, AO issued a notice of determination to E sustaining the proposed levy as to E’s nonprobate assets. Among the nonprobate assets reported on the estate tax return was an…