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Estate of Sels v. Commissioner

82 T.C. 64 (1984)

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Estate of Sels v. Commissioner

United States Tax Court
82 T.C. 64 (1984)

Facts

The Internal Revenue Service (IRS) issued a deficiency notice to the estate of Della Sells (estate) (plaintiff), claiming that the estate owed more than $2.4 million in estate tax. The estate and the estate’s coexecutors (plaintiffs) challenged the IRS’s determination by filing a petition against the IRS commissioner (defendant) with the United States Tax Court. The parties’ dispute involved the valuation of minority interests in certain timber property as of Sells’s death. Pursuant to Tax Court Rule 134 (now Rule 133), the estate and the coexecutors moved for a continuance of the scheduled trial date, citing the parties’ relatively recent exchange of expert reports regarding the valuation issue and claiming that they needed more time to consult with other experts and potential witnesses. The estate and coexecutors also noted that, due to other commitments, the parties’ respective appraisers could not yet provide current information about current timber volume, but the estate and coexecutors believed that such information would be available soon and that the parties could reach a stipulation about that issue. This was the estate and coexecutors’ first request for a continuance. The commissioner opposed a continuance.

Rule of Law

Issue

Holding and Reasoning (Hamblen, J.)

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Tax Practice and Procedure

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