Estate of Bessie I. Mueller, Deceased John S. Mueller, Personal Representative v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
BATCHELDER, Circuit Judge:
This is a case in which a taxpayer and the Internal Revenue Service (“IRS”) disagree over the effect of an audit adjustment to the taxpayer’s estate tax return. Specifically at issue are 8,924 shares of stock that the taxpayer undervalued when it filed the estate tax return, as a result of which the taxpayer underreported the taxable value of the shares and, consequently, underpaid its estate taxes. In addition, the government’s determination that the stock was worth more than taxpayer claimed also had the effect of creating an overpayment in capital gains tax…
2Cases cited14 opinions
- Bender v. Williamsport Area School DistrictSupreme Court of the United States · 1986
- United States v. DalmSupreme Court of the United States · 1990
- Mitchell v. MaurerSupreme Court of the United States · 1934
- Stone v. WhiteSupreme Court of the United States · 1937
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
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3Cited by25 opinions
- Estate of Frank Branson, Deceased Mary M. March v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- Hamdi Ex Rel. Hamdi v. NapolitanoCourt of Appeals for the Sixth Circuit · 2010
- Estate of Branson v. CommissionerUnited States Tax Court · 1999
- William D. Zack v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2002
- Intermet Corporation & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
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