New v. Commissioner
United States Tax Court
Held, an administrator of a decedent's estate, chargeable with notice of contingent tax liabilities, conducts a unilateral inquiry or investigation at his peril under sec. 6901(a)(1)(B), I.R.C. 1954, and Rev. Stat. sec. 3467 (31 U.S.C. sec. 192).
1Opinion of the Court
Forrester, Judge:
The respondent has determined deficiencies in the income tax of William J. Cunningham, deceased, as follows:
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Under section 6901(a)(1)(B) of the Internal Eevenue Code of 1954,1 and section 3467 of tlie Revised Statutes (31 U.S.C. sec. 192), respondent has determined that such deficiencies are the personal liability of the petitioner, as fiduciary of the Estate of William J. Cunningham, deceased, and that they are to be assessed against petitioner.
Respondent has now conceded the net liability remaining for 1948, consequently only the years 1956, 1957, and 1958…
2Cases cited6 opinions
- Minnie Viles, Administratrix of the Estate of Cloyd H. Viles, Deceased Harvey Viles Inez Viles Whaley Minnie Viles v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- United States v. BarnesDistrict Court, S.D. New York · 1887
- Irving Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- United States v. ClarkU.S. Circuit Court for New York · 1826
- McCourt v. CommissionerUnited States Tax Court · 1950
1 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Leigh v. CommissionerUnited States Tax Court · 1979
- Bank of West v. CommissionerUnited States Tax Court · 1989
- In Re Estate of Denman, Texas Court of Appeals, 4th District (San Antonio)2008
- Little v. CommissionerUnited States Tax Court · 1999
- Estate of Frost v. CommissionerUnited States Tax Court · 1993
9 more not listed; retrieve them via the Exa API.