Estate of Eversole v. Commissioner
United States Tax Court
Held, the Court is without jurisdiction with respect to the tax liability of the estate of John T. Eversole, deceased, for each of the years 1946, 1947, and 1948. Held, further, the Court has jurisdiction with respect to the individual liability of Ina G. Eversole Tapocik, and the petitioner Ina G. Eversole Tapocik is individually liable for the deficiency in tax determined by respondent for the year 1948.
1Opinion of the Court
OPINION.
Bruce, Judge:
The respondent determined deficiencies in income tax and additions to tax as follows:
[[Image here]]
Petitioners have conceded the correctness of the deficiencies determined 'by respondent for each of the years involved, and respondent has conceded that petitioners are not liable for additions to tax under section 293(b) of the Internal Revenue Code of 19391 for any of the years involved. A motion to dismiss the proceedings as to Ina G. Tapocik, individually, on the ground that no notice of deficiency had been issued to Ina G. Eversole (now Tapocik) individually, was filed…
2Cases cited12 opinions
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
- Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
- The FultonCourt of Appeals for the Second Circuit · 1931
- Sanborn v. HelveringCourt of Appeals for the Eighth Circuit · 1940
- Sanborn v. CommissionerUnited States Board of Tax Appeals · 1939
7 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Lerer v. CommissionerUnited States Tax Court · 1969
- Bunnel v. CommissionerUnited States Tax Court · 1968
- Estate of Stein v. CommissionerUnited States Tax Court · 1963
- Eversole v. CommissionerUnited States Tax Court · 1966
12 more not listed; retrieve them via the Exa API.