Legal Opinion

Estate of Bell v. Commissioner

United States Tax Court

Decided March 30, 1989No. Docket Nos. 11159-86, 11160-86Published

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

Estate of Laura V. Larsen Bell, Deceased, Laurel V. Bell-Cahill, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Charles C. Bell, Deceased, Laurel V. Bell-Cahill, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Bell v. Commissioner

Docket Nos. 11159-86, 11160-86

United States Tax Court

92 T.C. 714; 1989 U.S. Tax Ct. LEXIS 45; 92 T.C. No. 40;

March 30, 1989. March 30, 1989, Filed

Decision will be entered under Rule 155.

Ps elected, under sec. 6166, I.R.C. 1954, to pay a portion of their respective Federal estate tax liabilities on the…

2Cases cited14 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Flora v. United StatesSupreme Court of the United States · 1958
  3. Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
  4. Commissioner v. JacobsonSupreme Court of the United States · 1949
  5. Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985

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