Powell v. Comm'r. of Int'l. Rev., No. 08-9005
In an appeal from a tax court's post-trial decision to adopt the Commissioner of Internal Revenue's computation of the taxpayer's estate tax deficiency rather than the taxpayer's own computation, the order is affirmed where: 1) the tax court did not abuse its discretion in computing the amount of the deficiency; and 2) the tax court did not abuse its discretion by adopting the Commissioner's Rule 155 computation.
Filed September 11, 2009
Opinion by Judge Holloway
Patrick J. Urda, Attorney, Tax Division, United States Department of Justice, Washington, DC
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