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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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