Tax Court Memorandum by Julian I. Jacobs: Estate of Gertrude M. Ball et al. v. Commissioner

The United States Tax Court has published a memorandum opinion by Judge Julian I. Jacobs, a U.S. Tax Court Judge, entitled "Estate of Gertrude M. Ball et al. v. Commissioner of Internal Revenue."    The Tax Court upheld the denial of an estate's interest abatement request on a tax liability because the interest was not the result of the failure of the IRS to perform a ministerial or managerial act. The Tax Court rejected the estate's argument that the IRS caused the interest to accrue by not being aggressive in seeking collection of the estate's unpaid taxes.

See Also Tax Analysts: " Estate's Interest Abatement Request Properly Denied by IRS, Tax Court Holds." 2009 TNT 221-11, November 19, 2009.

Posted by Marc Patterson, Associate Editor, Wealth Strategies Journal