108 T.C. No. 4
UNITED STATES TAX COURT
ESTATE OF MARY K. WETHERINGTON, DECEASED,
MARY LOUISE RIPPLE, PERSONAL REPRESENTATIVE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19235-94. Filed February 10, 1997.
R extended the time for P to pay estate
tax under sec. 6161(a), I.R.C. P filed a
request for further extension of time to pay
tax under sec. 6161(a), I.R.C., which is now
pending with the Commissioner. P moved to
delay entry of decision until an extension of
time to pay tax under sec. 6161(a), I.R.C.,
no longer applies.
Held, under the rationale of Estate of
Bailly v. Commissioner, 81 T.C. 949 (1983),
we will delay entry of decision until P's
extension of time to pay tax under sec. 6161,
I.R.C., is no longer in effect.
Debra K. Smietanski, for petitioner.
James F. Kearney, for respondent.
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