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ESTATE OF HORVATH v. COMMISSIONER

Docket No. 2854-69.

59 T.C. 551 (1973)

ESTATE OF AKOS ANTHONY HORVATH, KLARI A. ERDOSS, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 18, 1973.

Attorney(s) appearing for the Case

Milton Brandon, for the petitioner.

Agatha L. Vorsanger, for the respondent.

STERRETT, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax return in the amount of $66,112.02 and a delinquency penalty under section 6651(a), I.R.C. 1954,1 in the amount of $13,222.40. The issues for our determination are:

(1) Whether an issue as to the validity of a debt of the decedent, Akos Anthony Horvath, is before this Court, where the statutory notice and pleadings were framed in terms...

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