Legal Opinion

Estate of Leonard Rosen, Bernice Siegel, Special Administrator v. Commissioner

United States Tax Court

Decided October 20, 2008No. 18844-04Unknown

1Opinion of the Court

131 T.C. No. 8

UNITED STATES TAX COURT ESTATE OF LEONARD ROSEN, DECEASED, BERNICE SIEGEL, SPECIAL ADMINISTRATOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18844-04. Filed October 20, 2008. On June 4, 2001, D’s estate (E) filed D’s 2000 Federal income tax return and paid the liability reported on that return. On July 7, 2001, E filed D’s Federal estate tax return and paid the liability reported on that return. On Aug. 13, 2001, R mistakenly assessed only part of the liability reported on the income tax return and refunded to E the portion of the income tax payment…

2Cases cited12 opinions

  1. United States v. DalmSupreme Court of the United States · 1990
  2. Lewis v. ReynoldsSupreme Court of the United States · 1932
  3. Jones v. Liberty Glass Co.Supreme Court of the United States · 1948
  4. Urbano v. Comm'rUnited States Tax Court · 2004
  5. Savage v. CommissionerUnited States Tax Court · 1999

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