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ESTATE OF SCULL v. COMMISSIONER

Docket No. 20201-90.

67 T.C.M. 2953 (1994)

T.C. Memo. 1994-211

Estate of Robert C. Scull, Deceased, Thomas Epstein and Marie Dickson, Executors v. Commissioner.

United States Tax Court.

Filed May 12, 1994.

Attorney(s) appearing for the Case

Thomas Epstein and Arthur Karger (specially recognized), 415 Madison Ave., New York, N.Y., for the petitioner. Steven R. Winningham and Patricia C. Dagati, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in decedent's Federal estate tax of $710,725.82 and an addition to tax under section 6651(a) of $151,303.76. Based upon expert valuation reports, respondent filed an Amendment to Answer on March 11, 1992, resulting in an increased deficiency, from $710,725.82 to $1,745,589, and an increased addition to tax, from $151,303...

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