Legal Opinion

Estate of Archer v. Commissioner

United States Tax Court

Decided February 2, 1984No. Docket No. 12011-78Unpublished

Petitioner filed its estate tax return after the due date and after the expiration of two extensions of time for filing. On this tax return, petitioner valued its assets as of the alternate valuation date. Held: Petitioner failed to make a valid election to use the alternate valuation date in valuing its assets. Sec. 2032(c), I.R.C. 1954.

1Opinion of the Court

ESTATE OF MARK E. ARCHER, DECEASED, AMERICAN FLETCHER NATIONAL BANK AND TRUST COMPANY OF INDIANAPOLIS, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Archer v. Commissioner

Docket No. 12011-78.

United States Tax Court

T.C. Memo 1984-57; 1984 Tax Ct. Memo LEXIS 617; 47 T.C.M. (CCH) 1027; T.C.M. (RIA) 84057;

February 2, 1984.

Petitioner filed its estate tax return after the due date and after the expiration of two extensions of time for filing. On this tax return, petitioner valued its assets as of the alternate valuation date.

Held: Petitioner failed to make a valid…

2Cases cited5 opinions

  1. Reiff v. CommissionerUnited States Tax Court · 1981
  2. Evans v. CommissionerUnited States Tax Court · 1967
  3. O'Brien v. CommissionerUnited States Tax Court · 1981
  4. Estate of Ryan v. CommissionerUnited States Tax Court · 1974
  5. Estate of Bradley v. CommissionerCourt of Appeals for the Sixth Circuit · 1975

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API