Estate of Walker v. Commissioner
United States Tax Court
Held, a notice of deficiency addressed to an estate mailed within 3 years of the date of the filing by decedent of his Federal income tax return is valid and timely absent a proper request for prompt assessment in accordance with the provisions of sec. 6501(d), I.R.C. 1954, even though, when the notice was mailed, the personal representative of the estate had been discharged and the assets of the estate have been distributed.
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Held, a notice of deficiency addressed to an estate mailed within 3 years of the date of the filing by decedent of his Federal income tax return is valid and timely absent a proper request for prompt assessment in accordance with the provisions of sec. 6501(d), I.R.C. 1954, even though, when the notice was mailed, the personal representative of the estate had been discharged and the assets of the estate have been distributed. Held, further, the ratification by the personal representative after her reappointment of the timely petition which was filed on behalf of the estate by an attorney…
1Opinion of the Court
Estate of Henry Walker, by Myrna J. Harms, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Walker v. Commissioner
Docket No. 703-86
United States Tax Court
90 T.C. 253; 1988 U.S. Tax Ct. LEXIS 17; 90 T.C. No. 19;
February 11, 1988; As amended February 24, 1988 February 11, 1988, Filed
Decision will be entered for the respondent.
Held, a notice of deficiency addressed to an estate mailed within 3 years of the date of the filing by decedent of his Federal income tax return is valid and timely absent a proper request for prompt assessment in accordance with…
2Cases cited11 opinions
- Hulburd v. CommissionerSupreme Court of the United States · 1935
- Krueger v. CommissionerUnited States Tax Court · 1967
- Harold Patz Trust v. CommissionerUnited States Tax Court · 1977
- Estate of Meyer v. CommissionerUnited States Tax Court · 1972
- Tarver v. CommissionerUnited States Tax Court · 1956
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