The recent U.S. Tax Court case, Estate of Kurt A. Amplatz, Security Bank & Trust Company v. Commissioner, offers QuickRead readers an opportunity to better understand what happens when the Service selects an estate’s 706 for audit, procedural issues that arise when motions for summary judgment are filed, and why penalty assessments under section 6662 are virtually always a triable issue. The ruling is cited extensively in the article because it provides those not familiar with a detailed roadmap of the Service’s statutory obligations and what is ultimately a triable issue. The recent U.S. Tax Court case, Estate of Kurt…