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.
Read Powell v. Comm'r. of Int'l. Rev., No. 08-9005
Appellate Information
Filed September 11, 2009
Judges
Opinion by Judge Holloway
Counsel
For Petitioner:
For Respondent:
Patrick J. Urda, Attorney, Tax Division, United States Department of Justice, Washington, DC
Nathan J. Hochman, Assistant Attorney General, Washington, DC
