Legal Opinion

Krueger v. Commissioner

United States Tax Court

Decided September 14, 1967No. Docket Nos. 2656-64, 2686-64PublishedCited by 51 opinions

1. Held, stipulated decisions entered by the Tax Court determining deficiencies against two estates are res judicata as to the liabilities of the estates in a later action involving the assessment of such liabilities against the transferees of the estates. 2. Held, an executor or administrator of an estate who files with the Commissioner the notice of fiduciary relationship in accordance with sec. 6903, I.R.C. 1954, but does not file notice that such fiduciary relationship…

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1. Held, stipulated decisions entered by the Tax Court determining deficiencies against two estates are res judicata as to the liabilities of the estates in a later action involving the assessment of such liabilities against the transferees of the estates. 2. Held, an executor or administrator of an estate who files with the Commissioner the notice of fiduciary relationship in accordance with sec. 6903, I.R.C. 1954, but does not file notice that such fiduciary relationship has terminated, has authority to bind such estate by agreeing to stipulated decisions before the Tax Court even though…

1Opinion of the Court

SimpsON, Judge:

In prior proceedings before this Court,1 stipulated decisions regarding the tax liabilities for the taxable years 1950 through 1957 of the Estate of William Krueger, deceased, and the Estate of Anna Krueger, deceased, were entered. These decisions, together with an uncontested assessment of income taxes against the Estate of Anna Krueger for the taxable years 1958 through 1960, resulted in total income tax assessments against the two estates of $709,225.42. Thereafter, the respondent determined that petitioner David Krueger was liable as transferee of the above two estates in…

2Cases cited27 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Cromwell v. County of SacSupreme Court of the United States · 1877
  3. Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
  4. Mercoid Corp. v. Mid-Continent Investment Co.Supreme Court of the United States · 1944
  5. Russell v. PlaceSupreme Court of the United States · 1877

22 more not listed; retrieve them via the Exa API.

3Cited by51 opinions

  1. Katz v. CommissionerUnited States Tax Court · 2000
  2. Richard M. Baptiste, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
  3. Harold Patz Trust v. CommissionerUnited States Tax Court · 1977
  4. Huddleston v. CommissionerUnited States Tax Court · 1993
  5. Gabriel J. Baptiste, Jr., Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994

46 more not listed; retrieve them via the Exa API.

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