Estate of Eddy v. Commissioner
United States Tax Court
The executor filed the Federal estate tax return in this case more than 18 months after the time prescribed by law (including extensions) for filing the return. The value of all property included in the gross estate was reported on the return as of the sec. 2032(a), I.R.C., alternate valuation date. R determined that decedent's gross estate must be valued as of the date of decedent's death, because the executor's alternate valuation election was invalid.
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The executor filed the Federal estate tax return in this case more than 18 months after the time prescribed by law (including extensions) for filing the return. The value of all property included in the gross estate was reported on the return as of the sec. 2032(a), I.R.C., alternate valuation date. R determined that decedent's gross estate must be valued as of the date of decedent's death, because the executor's alternate valuation election was invalid. Furthermore, R determined that the estate is liable for the addition to tax under sec. 6651(a), I.R.C., for the failure to file a timely…
1Opinion of the Court
ESTATE OF EDWARD H. EDDY, DECEASED, NATIONAL CITY BANK, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Eddy v. Commissioner
No. 235-99
United States Tax Court
115 T.C. 135; 2000 U.S. Tax Ct. LEXIS 55; 115 T.C. No. 10;
August 16, 2000, Filed
Decision will be entered for respondent.
The executor filed the Federal estate tax return in this
case more than 18 months after the time prescribed by law
(including extensions) for filing the return. The value of all
property included in the gross estate was reported on the return
as of the sec. 2032(a), I.R.C., alternate valuation…
2Cases cited12 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Nelson M. Blohm and Joann M. Blohm v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
- Estate of Frank Duttenhofer, Deceased, Albert J. Uhlenbrock and William Duttenhofer, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Duttenhofer v. CommissionerUnited States Tax Court · 1967
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