Commissioner of Internal Revenue v. Mccoy, Executor of the Estate of Mccoy (484 U.S. 3)
U.S. Supreme Court · decided October 19, 1987 · Supreme Court Database (Spaeth)
- Citation
- 484 U.S. 3 · 108 S. Ct. 217
- Decided
- October 19, 1987
- Term
- October Term 1987
- Vote
- 7–1
- Issue area
- Judicial Power
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Per Curiam. In this case, we are asked to determine whether the United States Court of Appeals exceeded its jurisdictional authority when, after affirming a decision of the United States Tax Court, it granted the taxpayer-estate’s request to forgive interest on the determined deficiency in estate tax and also to forgive a statutorily imposed late-payment penalty. We are constrained to hold that the Court of Appeals did exceed its authority. I Arthur H. McCoy died testate on April 23, 1980. His son, Robert McCoy, the respondent here, was appointed executor of his will. At his death, the decedent was the owner of an undivided interest in a family farm in Clinton County, Ohio. The then fair market value of that interest was $235,140. Under §2032A of the Internal Revenue Code of 1954, as amended, 26 U. S. C. § 2032A (1982 ed. and Supp. Ill), however, an estate may elect a special method for valuing certain real property for federal estate tax purposes. This alternative usually is elected if it produces a lower valuation and a lower tax. At the time relevant for the McCoy estate, the election was available only if the land in question was “qualified real property,” see § 2032A(b)(l), and only if the election was made “not later than the time prescribed by section 6075(a) for filing the [estate tax] return . . . (including extensions thereof) . . . .” 26 U. S. C. §2032A(d)(l) (1976…
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