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ESTATE OF FORMAN v. COMMISSIONER

Docket No. 905-76.

37 T.C.M. 1851 (1978)

T.C. Memo. 1978-510

Estate of Harry Forman, Milton Sanders, Executor v. Commissioner.

United States Tax Court.

Filed December 27, 1978.

Attorney(s) appearing for the Case

Harry Grossman, 515 Madison Ave., New York, N.Y., for the petitioner. Rudolph J. Korbel, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency in petitioner's Federal estate tax in the amount of $113,649.66, and a section 6651(a)1 addition to tax in the amount of $5,682.48. Petitioner has now conceded liability for the "late filing" penalty under section 6651(a), and the parties have agreed upon the value of one of decedent's partnership interests, so that the only remaining...

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