Estate of Irving Nemerov, Deceased, Bernice Midgorden, Personal Representative - Page 1

                                 T.C. Memo. 1998-186                                  

                               UNITED STATES TAX COURT                                

          ESTATE OF IRVING NEMEROV, DECEASED,                                         
          BERNICE MIDGORDEN, PERSONAL REPRESENTATIVE, Petitioner                      
          v. COMMISSIONER OF INTERNAL REVENUE, Respondent                             

               Docket No. 15625-97.                Filed May 20, 1998.                

                    D died on June 8, 1993.  In June 1994, the                        
               fiduciary of D's estate tendered a $225,400 payment to                 
               R for D's estimated Federal estate tax liability.  In                  
               May 1995, P filed D's Federal estate tax return and                    
               paid the balance due.  R assessed the amount of tax                    
               shown on the return and additions to tax of $67,135.73                 
               and $9,981.58 under sec. 6651(a)(1) and (2), I.R.C.,                   
               respectively.  Afterwards, R issued to D's estate a                    
               notice of deficiency listing a $9,716 deficiency and a                 
               $2,429 addition thereto under sec. 6651(a)(1), I.R.C.                  
               D petitioned the Court to redetermine the deficiency                   
               and the applicability of the additions to tax.                         
                    Held:  We lack jurisdiction to decide the                         
               applicability of the $67,135.73 addition to tax under                  
               sec. 6651(a)(1), I.R.C.                                                
                    Held, further, D's estate is liable for the                       
               additions to tax of $2,429 and $9,981.58 determined by                 
               R under sec. 6651(a)(1) and (2), I.R.C., respectively.                 

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