Estate of Orenstein v. Commissioner
United States Tax Court
R issued notices of deficiency to H and W determining Federal income tax liabilities for their 1981 and 1982 taxable years. H thereafter filed petitions for redetermination on behalf of himself and W's estate. Following H's subsequent death, his estate filed a Federal estate tax return which did not reflect a deduction for the still-pending income tax liabilities.
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R issued notices of deficiency to H and W determining Federal income tax liabilities for their 1981 and 1982 taxable years. H thereafter filed petitions for redetermination on behalf of himself and W's estate. Following H's subsequent death, his estate filed a Federal estate tax return which did not reflect a deduction for the still-pending income tax liabilities. Because a refund of the resulting estate tax overpayment is now time-barred, Ps seek to have a corresponding amount offset against the income tax liabilities pursuant to an equitable recoupment defense. HELD: Ps are entitled, under…
1Opinion of the Court
ESTATE OF HARRY ORENSTEIN, DECEASED, SUSAN CARRANO AND ARTHUR ORENSTEIN, PERSONAL REPRESENTATIVES AND ESTATE OF LORA ORENSTEIN, DECEASED, SUSAN CARRANO AND ARTHUR ORENSTEIN, PERSONAL REPRESENTATIVES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Orenstein v. Commissioner
No. 25687-85; No. 4930-88
United States Tax Court
T.C. Memo 2000-150; 2000 Tax Ct. Memo LEXIS 179; 79 T.C.M. (CCH) 1971;
April 26, 2000, Filed
Decisions will be entered under Rule 155.
R issued notices of deficiency to H and W determining
Federal income tax liabilities for their 1981 and 1982 taxable
years. H…
2Cases cited22 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Bull v. United StatesSupreme Court of the United States · 1935
- United States v. DalmSupreme Court of the United States · 1990
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