T.C. Memo. 2001-225
UNITED STATES TAX COURT
ESTATE OF MICHAEL J. THOMAS, DECEASED,
HELEN Z. THOMAS, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15734-99. Filed August 15, 2001.
William J. Abraham, for petitioner.
John J. Boyle, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined that
the estate was liable for the addition to tax under section
6651(a)(1), in the amount of $3,591, for failure to file its
Federal estate tax return timely.1 Based upon the estate tax
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code.
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