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Background
On June 4, 1997, we issued our opinion in the estate’s
consolidated cases.2 See Estate of Smith v. Commissioner, 108
T.C. 412 (1997). Our prior opinion dealt with respondent’s
disallowance of part of a deduction for a claim against the
estate under section 2053(a)(3). See id. at 413. We sustained
respondent’s estate tax deficiency determination because we found
that the proper valuation of the claim against the estate by
Exxon Corporation (Exxon) required consideration of the
settlement of the Exxon claim that occurred after decedent’s
death.3 See id. at 425. Our holding with respect to the estate
tax deficiency disposed of the need to address respondent’s
income tax deficiency determination. See id. at 425 n.13.
Pursuant to our opinion, the parties filed separate computations
under Rule 155. On January 12, 1998, we issued a supplemental
opinion resolving a disagreement between the parties with respect
to their computations. See Estate of Smith v. Commissioner, 110
T.C. 12 (1998). On March 31, 1998, the estate paid $646,325.76,
2Our original opinion consolidated two cases of the estate,
one dealing with an income tax deficiency determination (docket
No. 3976-95) and the other dealing with an estate tax
deficiency determination (docket No. 19200-94). The asserted
income tax deficiency was an alternate position taken by
respondent in the event we rejected his position in the estate
tax deficiency determination.
3We found that the validity and the enforceability of the
claim against decedent were uncertain as of the date of death.
See Estate of Smith v. Commissioner, 108 T.C. 412, 425 (1997).
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Last modified: May 25, 2011