Estate of Vriniotis v. Commissioner
United States Tax Court
At the time of his death, decedent was domiciled in Greece and was a citizen of both Greece and the United States. The Federal estate tax return for decedent's estate was not filed until over a year after the due date.
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At the time of his death, decedent was domiciled in Greece and was a citizen of both Greece and the United States. The Federal estate tax return for decedent's estate was not filed until over a year after the due date. Held: 1. Decedent having been a U.S. citizen at the time of his death, his estate is subject to U.S. estate tax under sec. 2001, I.R.C. 1954. 2. The Estate Tax Treaty with Greece does not exempt decedent's estate from U.S. estate tax. 3. There was no reasonable cause for the late filing of the return and the estate is liable for the addition to tax under sec. 6651(a)(1), I.R.C.…
1Opinion of the Court
Parker, Judge:
Respondent determined a deficiency in petitioner’s Federal estate tax of $10,035.95 and an addition to the tax under section 6651(a)(1)1 of $2,508.99. The issues for decision are:(1) Whether decedent was a citizen of the United States at the time of his death so that his estate is liable for U.S. estate tax;(2) Whether the Estate Tax Treaty with Greece exempts from U.S. estate tax the estate of a decedent who, at the time of his death, was domiciled in Greece and had dual U.S. and Greek citizenship; and(3) Whether there was reasonable cause for the late filing of the estate tax…
2Cases cited10 opinions
- Schneider v. RuskSupreme Court of the United States · 1964
- Afroyim v. RuskSupreme Court of the United States · 1967
- Cook v. TaitSupreme Court of the United States · 1924
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
- United States v. MathesonCourt of Appeals for the Second Circuit · 1976
5 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Estate of Cavenaugh v. CommissionerUnited States Tax Court · 1993
- Bank of West v. CommissionerUnited States Tax Court · 1989
- In Re CraddockCourt of Appeals for the Tenth Circuit · 1998
- Estate of Liftin v. United StatesCourt of Appeals for the Federal Circuit · 2014
- Russell v. Comm'rUnited States Tax Court · 2011
35 more not listed; retrieve them via the Exa API.