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RHEINSTROM v. C.I.R.

No. 90-1073.

925 F.2d 1066 (1991)

Celene RHEINSTROM, Administrator of the Estate of Mollie Rheinstrom Pollenz, Deceased, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 28, 1991.

Attorney(s) appearing for the Case

Bernard Maurice Lubelchek, Katten, Muchin & Zavis, Richard Rheinstrom, Chicago, Ill., for petitioner-appellant.

Peter K. Scott, I.R.S., Richard Farber, Gary R. Allen, Nancy G. Morgan, Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, Washington, D.C., Janice Lamartine, I.R.S., Chicago, Ill., for respondent-appellee.

Before BAUER, Chief Judge, POSNER and RIPPLE, Circuit Judges.

RIPPLE, Circuit Judge.

The Internal Revenue Service (IRS) issued a notice of deficiency to the estate of Mollie R. Pollenz. The estate petitioned the Tax Court for a redetermination of the deficiency. The court granted the IRS' motion for summary judgment. The estate appealed. For the following reasons, we affirm the judgment of the Tax Court.

I

BACKGROUND

The decedent, Mollie R. Pollenz, died...

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