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:

Edith Moates, Norman, OK

For Respondent:

Patrick J. Urda, Attorney, Tax Division, United States Department of Justice, Washington, DC

Nathan J. Hochman, Assistant Attorney General, Washington, DC

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