Estate of Kleemeier v. Comm'r of Internal Revenue

3 Citing cases

  1. Wentz v. Comm'r of Internal Revenue

    105 T.C. 1 (U.S.T.C. 1995)   Cited 4 times
    Considering the discrete severable events that made up a transaction that generates a purchase price adjustment

    We will not consider issues raised first on brief and not raised in the pleadings. Rollert Residuary Trust v. Commissioner, 80 T.C. 619, 636 (1983), affd. on other grounds 752 F.2d. 1128 (6th Cir.1985); Estate of Kleemeier v. Commissioner, 58 T.C. 241, 250 (1972). Petitioners were not afforded the opportunity to address that issue; therefore, they did not attempt to show that section 6662(b)(2) should not be applied.

  2. Rocker-Citizens Nat'l Bank v. Comm'r of Internal Revenue (In re Estate of Sparling)

    60 T.C. 330 (U.S.T.C. 1973)   Cited 6 times

    Eleanor C. Shomaker, supra at 201. See also Estate of Lyla B. Kleemeier, 58 T.C. 241 (1972). Petitioner on brief also claimed that one-half of the family allowance must be taken as a deduction in determining Raymond's estate tax and a reconsideration of Raymond's estate tax and its effect on Isabelle's return is in order.

  3. Kate Froman Trust v. Comm'r of Internal Revenue

    58 T.C. 512 (U.S.T.C. 1972)   Cited 5 times

    Accordingly, we hold that such claim is untimely and cannot be considered in deciding this case. Estate of Lyla D. Kleemeier, 58 T.C. 241(1972). Although it will be necessary to recompute the amount of the charitable contribution as a result of the additional administrative expenses that have been incurred in this litigation, the value of such contribution should be computed by using the same method as was used on the return.