Baptiste v. Commissioner
United States Tax Court
In previous opinions it was determined that each petitioner was personally liable for unpaid estate tax to the extent of the value, at the time of decedent's death, of each petitioner's interest in the proceeds of insurance on decedent's life.
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In previous opinions it was determined that each petitioner was personally liable for unpaid estate tax to the extent of the value, at the time of decedent's death, of each petitioner's interest in the proceeds of insurance on decedent's life. Held: (1) Each petitioner is liable for interest under Federal law on the amount of his personal liability for unpaid estate tax from the due date of the transferor's estate tax return; and (2) the limitation imposed by sec. 6324(a)(2) does not apply to petitioners' respective liabilities for such interest.
1Opinion of the Court
Whitaker, Judge:
This matter is before the Court on respondent’s separate motions for summary judgment filed pursuant to Rule 121.2 The issue for decision is whether petitioners are liable for interest under Federal law on the amount of their personal liabilities for unpaid estate tax from the due date of the transferor’s estate tax return.
FINDINGS OF FACT
On September 26, 1981, Gabriel J. Baptiste (hereinafter decedent) died possessing incidents of ownership with respect to certain insurance policies on his life. On or about November 16, 1981, Gabriel J. Baptiste, Jr., and Richard M. Baptiste…
2Cases cited8 opinions
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
- Stein v. CommissionerUnited States Tax Court · 1962
- Groetzinger v. CommissionerUnited States Tax Court · 1977
- Patterson v. SimsCourt of Appeals for the Fifth Circuit · 1960
3 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Richard M. Baptiste, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- Pert v. CommissionerUnited States Tax Court · 1995
- United States v. Finley HilliardCourt of Appeals for the Fifth Circuit · 2014
- Riffe v. United States of America (In Re Pert)United States Bankruptcy Court, M.D. Florida · 1996
- O'Sullivan v. CommissionerUnited States Tax Court · 1994
13 more not listed; retrieve them via the Exa API.