- 2 - requirements of section 7430(c)(4)(A)(ii).1 The issue for decision is whether section 7430(c)(4)(D) applies in determining the net worth requirements for an estate seeking review under section 6404(i) of a failure to abate interest. After respondent issued a final determination denying petitioner’s request to abate interest, a timely petition for review under section 6404 was filed with this Court. Respondent thereafter filed a motion to dismiss for lack of jurisdiction, with exhibits, to which petitioner filed an objection, with exhibits. The Court held a hearing on the motion, received an additional exhibit, and granted leave for the parties to file briefs supporting their positions. We decide the motion based on the hearing record, respondent’s motion, petitioner’s objection, the exhibits, and the briefs. Background Edward J. Kunze (decedent) died on December 18, 1992. Carol Ann Hause is the independent executor for the estate of decedent (estate). The executor resided in East Lansing, Michigan, at the time the petition was filed. Decedent was domiciled in Cook County, Illinois, on the date of death, and his estate was probated in Cook County, Illinois. The value of the gross estate as of December 18, 1992 (decedent’s date of death), as agreed to 1 Unless otherwise indicated, all section references are to the Internal Revenue Code.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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