Armstrong v. Commissioner
United States Tax Court
D transferred a substantial portion of his assets to Ps within 3 years of his death. After paying the Federal gift taxes associated with these gifts, D was nearly insolvent. Following D's death, R determined a deficiency in Federal estate tax due from D's estate attributable to the estate's failure to include in the gross estate the gift taxes that D paid on the aforementioned gifts. See sec. 2035(c), I.R.C.
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D transferred a substantial portion of his assets to Ps within 3 years of his death. After paying the Federal gift taxes associated with these gifts, D was nearly insolvent. Following D's death, R determined a deficiency in Federal estate tax due from D's estate attributable to the estate's failure to include in the gross estate the gift taxes that D paid on the aforementioned gifts. See sec. 2035(c), I.R.C. R subsequently issued notices of transferee liability to Ps who filed timely petitions for redetermination with the Court. Ps filed motions for partial summary judgment alleging that they…
1Opinion of the Court
FRANK ARMSTRONG, III, TRANSFEREE, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Armstrong v. Commissioner
No. 7267-98; No. 7269-98; No. 7270-98; No. 7274-98
United States Tax Court
114 T.C. 94; 2000 U.S. Tax Ct. LEXIS 5; 114 T.C. No. 5;
February 28, 2000, Filed
Orders denying petitioners' motions for partial summary judgment will be issued.
D transferred a substantial portion of his assets
to Ps within 3 years of his death. After paying the
Federal gift taxes associated with these gifts, D was
nearly insolvent. Following D's death, R determined a
deficiency in Federal estate tax…
2Cases cited11 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Zaentz v. CommissionerUnited States Tax Court · 1988
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