Estate of Gordon H. Bartels, Deceased, Sally A. Jouris and Thomas G. Bartels, Executors, and Estate of Violet J. Bartels, Deceased, Sally A. Jouris and Thomas G. Bartels, Executors - Page 1

                                   106 T.C. No. 24                                    


                               UNITED STATES TAX COURT                                


          ESTATE OF GORDON H. BARTELS, DECEASED, SALLY A. JOURIS AND THOMAS           
          G. BARTELS, EXECUTORS, AND ESTATE OF VIOLET J. BARTELS, DECEASED,           
          SALLY A. JOURIS AND THOMAS G. BARTELS, EXECUTORS, Petitioners v.            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 13886-90.                    Filed June 11, 1996.           


                    Both parties moved for summary judgment based                     
               solely on the issue whether this Court has jurisdiction                
               to allow, by way of equitable recoupment, an offset of                 
               a barred estate tax overpayment resulting from the                     
               deductibility of the stipulated income tax deficiency                  
               herein as a debt of the decedent, Gordon Bartels.                      
               Held, this Court has such jurisdiction.  Estate of                     
               Mueller v. Commissioner, 101 T.C. 551 (1993),                          
               reaffirmed and applied.                                                


               John E. Pfau, for petitioners.                                         
               John F. Eiman and Thomas L. Fenner, for respondent.                    









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