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* Leon Israel, Jr., died a resident of New Jersey.
Petitioners' counsel argues that docket No. 31588-88,
involving the Estate of Leon Israel, Jr., is appealable to the
U.S. Court of Appeals for the District of Columbia Circuit
because petitioners' counsel, Herbert Stoller, is also a co-
executor of the Estate of Leon Israel, Jr., and resided in
Bermuda at the time the petition was filed. In this regard, we
note that the petition in docket No. 31588-88 was filed not by
Herbert Stoller, as executor of the Estate of Leon Israel, Jr.,
but by Barry W. Gray, as executor of the Estate of Leon
Israel, Jr.
Section 7482(b)(1)(A) provides that decisions of the Tax
Court may be reviewed by the U.S. Court of Appeals for the
circuit in which is located:
(A) in the case of a petitioner seeking
redetermination of tax liability other than a
corporation, the legal residence of the petitioner,
Because Herbert Stoller is not a petitioner in docket No.
31588-88, it is unclear whether said docket would be appealable
to the U.S. Courts of Appeals for the Second and/or Third Circuit
or to the U.S. Court of Appeals for the District of Columbia
Circuit. Accordingly, we are not bound by the opinion of the
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