United States Second Circuit
Estate of Thompson v. Comm'r of Internal Rev., 06-0815
Judgment of tax court valuing an estate's interest in a closely held company and declining to impose an underpayment penalty against petitioners is vacated where there is a conceded error in the tax court's calculation and because the court's findings are insufficient to support the application of the reasonable cause exception to the otherwise mandatory underpayment penalty.
Appellate Information
- Decided 08/23/2007
- Published 08/23/2007
Judges
- DENNIS JACOBS, Chief Judge:, Before: JACOBS, Chief Judge, LEVAL and POOLER, Circuit Judges.
Court
- United States Second Circuit
Counsel
- For Appellant:
- Joshua M. Rubins (Robert H. Goldie and Kirk H. O'Ferrall, on the brief), Satterlee Stephens Burke & Burke LLP, New York, NY, for Appellants.
- For Appellees:
- Richard Farber (Steven W. Parks, on the brief), for Eileen J. O'Connor, Assistant Attorney General, Tax Division, Department of Justice, Washington, D.C., for Appellee.