Legal Opinion

Armstrong v. Commissioner

United States Tax Court

Decided February 28, 2000No. 7267-98; No. 7269-98; No. 7270-98; No. 7274-98Published

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

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  3. Naftel v. CommissionerUnited States Tax Court · 1985
  4. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
  5. Zaentz v. CommissionerUnited States Tax Court · 1988

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