ESTATE OF BRANSON v. COMMISSIONER

Docket No. 10028-95.

113 T.C. 6 (1999)

ESTATE OF FRANK A. BRANSON, DECEASED, MARY M. MARCH, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 13, 1999.


Attorney(s) appearing for the Case

Robert A. Mills, Marco L. Quazzo, and Mary Catherine Wirth, for petitioner.

Rebecca T. Hill, Bryce A. Kranzthor, and Elizabeth Groenewegen, for respondent.


OPINION

PARR, Judge:

In Estate of Branson v. Commissioner, T.C. Memo. 1999-231 (Branson I), we redetermined the increased value of the shares of Savings Bank of Mendocino County (Savings) and Bank of Willits (Willits) included in decedent's gross estate. We now consider whether this Court has authority to apply equitable recoupment in light of the opinion of the Court of Appeals for the Sixth Circuit in...

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