Towe
United States Tax Court
R determined several Federal income tax deficiencies regarding a particular transaction and taxable period. The cases were petitioned and resulted in settlement by R and all Ps. This Court entered the net result of their agreement in the form of an agreed decision document. Subsequently, R determined a gift tax deficiency with respect to the same transaction and period of time.
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R determined several Federal income tax deficiencies regarding a particular transaction and taxable period. The cases were petitioned and resulted in settlement by R and all Ps. This Court entered the net result of their agreement in the form of an agreed decision document. Subsequently, R determined a gift tax deficiency with respect to the same transaction and period of time. Ps contend that respondent is precluded from making the gift tax determinations under sec. 6212, I.R.C., and the doctrines of res judicata or collateral estoppel. Held: Under these circumstances, neither sec. 6212,…
1Opinion of the Court
ANDREW C. TOWE, SARA TOWE HORSFALL, KRISTIN HARTLEY, KAREN JAMES, THOMAS E. TOWE, JAMES T. TOWE, KRISTOFER E. TOWE, TAMARA JAMES JENSEN, KARLA JAMES, DAVID E. JAMES, ERIC R. JAMES, ARVID HARTLEY, ANDREW C. HARTLEY, C. FLORENCE TOWE, TOWE FARMS, INC. TRUST, & GRANT INVESTMENTS FUND, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; TOWE FARMS INC., TRANSFEREE, W. EDWARD & C. FLORENCE TOWE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Towe
Docket Nos. 26854-89, 6227-90
United States Tax Court
T.C. Memo 1992-689; 1992 Tax Ct. Memo LEXIS 733; 64 T.C.M. (CCH) 1424;
December 2,…
2Cases cited33 opinions
- Allen v. McCurrySupreme Court of the United States · 1980
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- United States v. DalmSupreme Court of the United States · 1990
28 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Batchelor-Robjohns v. United StatesCourt of Appeals for the Eleventh Circuit · 2015
- Anne (Sandy) Batchelor-Robjohns v. United StatesCourt of Appeals for the Eleventh Circuit · 2015