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UHLENBROCK v. COMMISSIONER

Docket No. 2076-75.

67 T.C. 818 (1977)

ALBERT J. UHLENBROCK AND SYLVIA J. UHLENBROCK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 17, 1977.

Attorney(s) appearing for the Case

Kenneth R. Hughes, for the petitioners.

Joel V. Williamson, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1973 in the amount of $3,021.65. The sole issue before us is whether petitioners are entitled to a deduction in respect of that portion of a section 6651(a)1 addition to tax incurred by the Estate of Frank Duttenhofer which was paid in 1973 by Albert J. Uhlenbrock as a fiduciary of such estate.

The parties submitted...

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