Case: U.S. Tax Court Upholds IRS’s Estate Tax Deficiency, Transferee Liability Against Executor (IRC §6651) (T.C. Memo)

The U.S. Tax Court upheld the IRS’s determination that the estate was liable for an estate tax deficiency and addition to tax, and that the taxpayer was liable as a transferee. Taxpayer, the executor of his mother’s estate, failed to file an estate tax return timely and improperly valued and excluded certain assets. The court found that the estate could not elect either the alternate valuation or the conservation easement exclusion due to the late filing. It upheld the IRS’s higher valuations of estate assets, including real property and a business interest, based on expert testimony. The court also sustained ...