Porter v. Commissioner
United States Tax Court
Reasonable expenses paid in litigating the liability of an estate for estate tax in a case arising from the determination by respondent of the liability of the transferor estate against transferees are deductible in computing the estate tax liability of the transferees.
1Opinion of the Court
supplemental opinion
Scott, Judge:
The original opinion in this case at 49 T.C. 207 (1967), promulgated on December 13,1967, directed entry of decisions under Rule 50. On March 4, 1969, the parties each filed computations under Rule 50, the only variance between respondent’s computations and petitioners’ computations being that in petitioners’ computations deduction was claimed in computing the estate tax of the Estate of Alice M. Porter, transferor, for attorneys’ fees and related expenditures in prosecuting this case.1
Petitioners filed a brief in support of their computation, and at the…
2Cases cited16 opinions
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
- Commissioner of Internal Revenue v. Estate of Harry A. Ellis, Deceased, Helen R. Ellis, Bernard B. Largman and Dan Denenberg, ExecutorsCourt of Appeals for the Third Circuit · 1958
- Krueger v. CommissionerUnited States Tax Court · 1967
- First Western Bank & Trust Co. v. CommissionerUnited States Tax Court · 1959
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3Cited by6 opinions
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Baptiste v. CommissionerUnited States Tax Court · 1992
- Baptiste v. CommissionerUnited States Tax Court · 1992
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Gillum v. CommissionerUnited States Tax Court · 1984
1 more not listed; retrieve them via the Exa API.