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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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