Estate of Myers v. Comm'r
United States Tax Court
P asks us to review a determination by IRS Appeals sustaining a lien notice and a notice of proposed levy to collect delinquent installment payments of estate tax. The gravamen of P's complaint is that R abused his discretion during the 10-year period before the delinquency by not pursuing collection from nonprobate assets not under P's control.
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P asks us to review a determination by IRS Appeals sustaining a lien notice and a notice of proposed levy to collect delinquent installment payments of estate tax. The gravamen of P's complaint is that R abused his discretion during the 10-year period before the delinquency by not pursuing collection from nonprobate assets not under P's control. Following the CDP hearing, the settlement officer prioritized collection actions first against nonprobate assets and certain jointly owned probate property. P misunderstands the I.R.C. sec. 6324(a)(1) special estate tax lien, which attaches…
1Opinion of the Court
ESTATE OF RUBEN A. MYERS, DECEASED, KEN NORTON, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Myers v. Comm'r
Docket No. 20823-15L.
United States Tax Court
T.C. Memo 2017-11; 2017 Tax Ct. Memo LEXIS 10; 113 T.C.M. (CCH) 1045;
January 10, 2017, Filed
Decision will be entered for respondent.
P asks us to review a determination by IRS Appeals sustaining a lien notice and a notice of proposed levy to collect delinquent installment payments of estate tax. The gravamen of P's complaint is that R abused his discretion during the 10-year period before the delinquency by not…
2Cases cited10 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
- Murphy v. Comm'rUnited States Tax Court · 2005
- United States v. Warren B. Davis, Trustee of the Warren B. Davis Revocable Living Trust, and Westwood Industrial Park, Ltd.Court of Appeals for the Eighth Circuit · 1995
- Lime Cola Co. v. CommissionerUnited States Tax Court · 1954
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