- 3 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011