ESTATE OF KELLEY v. COMMISSIONER

Docket Nos. 3236-73, 3237-73.

63 T.C. 321 (1974)

ESTATE OF J. W. KELLEY, DECEASED, N. RAY KELLEY, INDEPENDENT EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MARGARET I. KELLEY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1974.


Attorney(s) appearing for the Case

Edward R. Smith, for the petitioners.

John W. Dierker, for the respondent.


OPINION

FEATHERSTON, Judge:

In these consolidated proceedings, respondent determined the following deficiencies in the gift tax of petitioners:

    Docket No.                  Year    Deficiency

    3236-73 ----------------    1954    $8,869.65
    3237-73 ----------------    1954    11,441.62

Respondent also determined that additions to the tax were applicable under section 6651(a)

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