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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