Albert Strangi, Deceased, Rosalie Gulig, Independent Executrix, Petitioner-appellant, v. Commissioner of Internal Revenue, Respondent-appellee, 429 F.3d 1154 (5th Cir. 2005)

Annotate this Case
U.S. Court of Appeals for the Fifth Circuit - 429 F.3d 1154 (5th Cir. 2005) November 7, 2005

Norman Arthur Lofgren, George Tomas Rhodus, Michael C. Kelsheimer, Looper Reed & McGraw, Dallas, TX, for Strangi.

Michael J. Haungs, John A. Nolet, Jonathan S. Cohen, Tax Div., App. Section, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Charles Casazza, Clerk, U.S. Tax Court, Emily A. Parker, IRS, Washington, DC, for C.I.R.

Milford B. Hatcher, Jr., Jones Day, Atlanta, GA, for American College of Trust and Estate Counsel, Amicus Curiae.

Petition for Review of an Order of the Internal Revenue Service (Tax Ct.).

ON PETITION FOR REHEARING

Before REAVLEY, JOLLY and PRADO, Circuit Judges.

PER CURIAM:


IT IS ORDERED that the unopposed petition for rehearing is GRANTED. This case is REMANDED to the Tax Court for the limited purpose of determining allowable administrative expenses, including attorney's fees.

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.