§3770

12 cases·12 cited

Statute Text — 26 U.S.C. §3770

Statute text not available for this section.

12 Citing Cases

Estate of Algerine Allen Smith, Deceased; James Allen Smith, Executor, Petitioners 123 T.C. No. 2 · 2004

eport's only citation regarding the section 6402(a) analysis is Belloff v. Commissioner, 996 F.2d 607 (2d Cir. 1993), affg. T.C. Memo. 1991-350. Reliance on Belloff is misplaced. ¹ Sec. 6402(a) was first added to the Internal Revenue Code of 1939 at sec. 3770(a)(4) by the Tax Administrative Amendments of 1949, ch. 517, sec. 9(a), Pub. L. 271, and was moved to sec. 6402 by the Internal Revenue Code of 1954, ch. 736, 68 Stat. 730. It has been amended by the Internal Revenue Service Restructuring a

Estate of Smith v. Commissioner 123 T.C. 15 · 2004

nes, Wherry, Kroupa, and Holmes, JJ., agree with this dissenting opinion. The amount of total interest due was determined in reference to the estate’s tax liability of $385,747.17. Sec. 6402(a) was first added to the Internal Revenue Code of 1939 as sec. 3770(a)(4) by the Tax Administrative Amendments of 1949, ch. 517, sec. 9(a), 63 Stat. 669, and was moved to sec. 6402 by the Internal Revenue Code of 1954, ch. 736, 68 Stat. 730. It has been amended by the Internal Revenue Service Restructuring

Fortugno v. Commissioner 41 T.C. 316 · 1963

New York Trust Co. v. Commissioner 26 T.C. 257 · 1956

Quirk v. Commissioner 15 T.C. 709 · 1950

Estate of Hansen v. Commissioner 9 T.C. 108 · 1947

Edwin J. Schoettle Co. v. Commissioner 3 T.C. 712 · 1944

Moore v. Commissioner 1 T.C. 14 · 1942

Negron v. United States 553 F.3d 1013 · Cir.

Carol Negron v. United States · Cir.

Georg Schaeffler v. United States 889 F.3d 238 · Cir.

Georg Schaeffler v. United States · Cir.