115 T.C. No. 11
UNITED STATES TAX COURT
ESTATE OF GLENN G. FORGEY, DECEASED, LYLE A.
FORGEY, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13077-98. Filed August 16, 2000.
An estate tax return was delinquently filed on
behalf of decedent’s estate (E). R assessed the tax
reported on the return and an addition to tax for late
filing. R subsequently examined E’s return and
determined a deficiency and an addition to tax for late
filing relating to such deficiency. The parties
settled the issues relating to the estate tax
liability. As part of the settlement, E agreed to
various increases to the taxable estate. However, due
to R’s allowance of a deduction for interest expense,
the settlement produced an overassessment in tax.
E disputes the late filing addition to tax
assessed by R prior to the issuance of the notice of
deficiency. R contends that this Court lacks
jurisdiction over such addition to tax pursuant to sec.
6665(b), I.R.C. E contends that this Court has
jurisdiction over a portion of the addition to tax
under sec. 6665(b)(1), I.R.C., given that E agreed to
increases in the taxable estate through the deficiency
procedures.
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