Estate of Heller v. Comm'r
United States Tax Court
E held a 99% interest in L, which held an account with MS as its only asset. L distributed to E a portion of the funds from the MS account, and E used those funds to pay estate taxes and administrative expenses. Before E could distribute its remaining assets to D's beneficiaries, MS' chairman was arrested on, and pleaded guilty to, charges relating to a Ponzi scheme.
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E held a 99% interest in L, which held an account with MS as its only asset. L distributed to E a portion of the funds from the MS account, and E used those funds to pay estate taxes and administrative expenses. Before E could distribute its remaining assets to D's beneficiaries, MS' chairman was arrested on, and pleaded guilty to, charges relating to a Ponzi scheme. As a result of the Ponzi scheme, the MS account became worthless, and E, on its Federal estate tax return, deducted a theft loss relating to its interest in L. In a notice of deficiency issued to E, R determined that E was not…
1Opinion of the Court
ESTATE OF JAMES HELLER, DECEASED, BARBARA H. FREITAG, HARRY H. FALK, AND STEVEN P. HELLER, CO-EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Heller v. Comm'r
Docket No. 11390-12
United States Tax Court
2016 U.S. Tax Ct. LEXIS 28; 147 T.C. No. 11;
September 26, 2016, Filed
An appropriate order will be issued, and decision will be entered under Rule 155.
E held a 99% interest in L, which held an account with MS as its only asset. L distributed to E a portion of the funds from the MS account, and E used those funds to pay estate taxes and administrative expenses.…
2Cases cited7 opinions
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- Davis v. Michigan Department of the TreasurySupreme Court of the United States · 1989
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- White v. CommissionerUnited States Tax Court · 1967
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Moss v. Comm'rUnited States Tax Court · 2017