Estate of Helen Moore Quirk v. Commissioner of Internal Revenue

OPINION

This estate tax problem developed after the executor of the estate of Helen Moore Quirk received a statutory notice of deficiency in the estate’s tax return in the sum of $135,210, and an additional penalty assessment of 50 percent of the underpayment for alleged fraud. Internal Revenue Code of 1954, section 6653(b), 26 U.S.C. §§ 6653(b). A statement was attached which showed the underpayment resulted from the Commissioner’s recomputation of the taxable estate from $21,250 to $472,766. A timely petition by the estate for redetermination of the deficiency was filed in the Tax Court…