Estate of Meyer v. Commissioner
United States Tax Court
Held: Tax Court has no jurisdiction over R's determination disallowing P's election under sec. 6166, I.R.C. 1954, as amended, to pay estate tax in installments. Such determination is divorced from determination of P's entitlement to deduction for administration expense of interest.
1Opinion of the Court
OPINION
Cantrel, Special Trial Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike as to the payment of Federal estate tax under sec. 6166, I.R.C. 1954,1 filed on July 23, 1984. This motion was called for hearing at the motions session of the Court at Washington, D.C., on January 16, 1985.2 Counsel for petitioners and respondent appeared and presented argument.
Respondent, in his notice of deficiency dated March 14,1984, determined an estate tax deficiency of $1,276,569.47. This deficiency is based in part upon an increased valuation of…
2Cases cited7 opinions
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Foster v. Comm'rUnited States Tax Court · 1983
- Breman v. CommissionerUnited States Tax Court · 1976
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
2 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Saso v. CommissionerUnited States Tax Court · 1989
- 1983 Western Reserve Oil & Gas Co. v. CommissionerUnited States Tax Court · 1990
- Phillips Petroleum Co. v. CommissionerUnited States Tax Court · 1989
- Estate of Roski v. Comm'rUnited States Tax Court · 2007
- Estate of Bell v. CommissionerUnited States Tax Court · 1989
11 more not listed; retrieve them via the Exa API.