Executor Personal Liability for Estate Taxes: Lessons From the Estate of Spenlinhauer Case

In Estate of Spenlinhauer v. Commissioner, T.C. Memo. 2025-134, the United States Tax Court upheld a multimillion dollar estate tax deficiency and penalties against both an estate and its executor personally. The case illustrates how delayed filings, unsupported valuations, and improper asset transfers can expose executors and beneficiaries to severe financial consequences long after a death occurs.