United States Tenth Circuit

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.

Appellate Information

• Decided 09/11/2009
• Published 09/11/2009

Judges

• HOLLOWAY, Circuit Judge., Before BRISCOE, HOLLOWAY, and MURPHY, Circuit Judges.

Court

• United States Tenth Circuit

Counsel

• For Appellant:
  
• Edith Moates, Norman, Oklahoma, for Petitioner-Appellant.


• For Appellees:
  
• Patrick J. Urda, Attorney, Tax Division, United States Department of Justice (Nathan J. Hochman, Assistant Attorney General, and Richard Farber, Attorney, Tax Division, United States Department of Justice, with him on the brief), Washington, D.C., for Respondent-Appellee.