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ESTATE OF O'CONNOR v. COMMISSIONER

Docket No. 7156-74.

69 T.C. 165 (1977)

ESTATE OF A. LINDSAY O'CONNOR, DECEASED, DERMOD IVES AND UNITED STATES TRUST COMPANY OF NEW YORK, EXECUTORS, TRUST UNDER ARTICLE FOURTH, SUBDIVISION I, OF THE WILL OF A. LINDSAY O'CONNOR, DECEASED (MARITAL TRUST), DERMOD IVES AND UNITED STATES TRUST COMPANY OF NEW YORK, TRUSTEES, AND OLIVE B. PRICE, ROBERT L. AND LUCILLE S. BISHOP, AND DONALD F. AND EDNA G. BISHOP, INDIVIDUALLY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 3, 1977.

Attorney(s) appearing for the Case

Kenneth W. Greenawalt and John F. Williamson, for the petitioners Estate of A. Lindsay O'Connor, deceased, Dermod Ives and United States Trust Co. of New York, executors, and Trust under Article Fourth, subdivision I, of the will of A. Lindsay O'Connor, deceased (marital trust), Dermod Ives and United States Trust Co. of New York, trustees.

Morris Gitlitz and Eugene E. Peckham, for the petitioners Olive B. Price, Robert L. and Lucille S. Bishop, and Donald F. and Edna G. Bishop.

Rudolph J. Korbel and David A. Schmudde, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined the following deficiencies in the petitioners' Federal income taxes:

                             TYE Oct. 31—     Deficiency
Estate of A. Lindsay
  O'Connor ----------------------   1969      $275,443.00
                                    1970       255,603.90
                                    1971       174,335.76

                             TYE Dec....

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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