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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