Estate of Israel v. Commissioner
Court of Appeals for the D.C. Circuit
1Opinion of the Court
Opinion for the Court filed by Circuit Judge RANDOLPH.
RANDOLPH, Circuit Judge:
This is an appeal from a decision of the Tax Court sustaining the position of the Commissioner of Internal Revenue regarding the tax treatment of certain losses. The appellants are the co-executors of an estate and the decedent’s widow. The case turns on venue. Decisions of the Tax Court may be appealed to the circuit courts of appeals. The venue of a court of appeals depends on the residence of the petitioner in the Tax Court, but when the taxpayer is an estate, what controls? An estate has no legal residence. Does…
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Kerotest Manufacturing Co. v. C-O-Two Fire Equipment Co.Supreme Court of the United States · 1952
- Semmes Motors, Inc., Suing on Behalf of Itself and Together With Ford Dealers Alliance, Inc., Etc. v. Ford Motor CompanyCourt of Appeals for the Second Circuit · 1970
- Panhandle Eastern Pipe Line Co. v. Federal Power CommissionSupreme Court of the United States · 1945
- Herbert and Marsha Stoller v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1993
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3Cited by4 opinions
- Buckrey v. Comm'rUnited States Tax Court · 2017
- CRI-Leslie, LLC v. Comm'rUnited States Tax Court · 2016
- Brown v. CommissionerCourt of Appeals for the Sixth Circuit · 2002
- Trust U/W/O BH and MW Namm F/B/O Andrew I. Namm, Andrew I. Namm and James Doran, Trustees, Transferee v. CommissionerUnited States Tax Court · 2018