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OPINION
COLVIN, Judge: This matter is before the Court on
petitioner's Motion to Stay Proceedings. In the motion,
petitioner asks the Court to postpone entry of decision until
either (1) An extension of time to pay petitioner's Federal
estate tax under section 6161(a) is no longer in effect and any
appeal of respondent's denial of an extension is final, or (2)
petitioner fully pays its outstanding Federal tax liability and
related interest, whichever happens first. The parties agree
that, if we grant the motion, petitioner may deduct interest that
it would not be allowed to deduct if we had entered a decision.
Sec. 6512(a).
We conclude that it is appropriate to delay entry of
decision until an extension of time for the payment of
petitioner's estate tax under section 6161 is no longer in effect
and any administrative appeal of respondent's denial of such an
extension is final, or until petitioner fully pays its Federal
tax liability and related interest, whichever occurs first.
This is a case of first impression. However, in a related
context, we delayed entry of decision where the taxpayer elected
to defer payment of estate tax for 10 years under section 6166.
Estate of Bailly v. Commissioner, 81 T.C. 949 (1983).
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Last modified: May 25, 2011