Estate of Archer v. Commissioner
United States Tax Court
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
- Reiff v. CommissionerUnited States Tax Court · 1981
- Evans v. CommissionerUnited States Tax Court · 1967
- O'Brien v. CommissionerUnited States Tax Court · 1981
- Estate of Ryan v. CommissionerUnited States Tax Court · 1974
- Estate of Bradley v. CommissionerCourt of Appeals for the Sixth Circuit · 1975