ESTATE OF O'BRIEN v. COMMISSIONER

Docket Nos. 4178-74, 4179-74.

37 T.C.M. 799 (1978)

T.C. Memo. 1978-185

Estate of Joseph H. O'Brien, Deceased, Lucille S. Noel, Executrix, and Lucy V. O'Brien v. Commissioner. Macadam Construction Company, Inc. v. Commissioner.

United States Tax Court.

Filed May 22, 1978.


Attorney(s) appearing for the Case

Victor Chini, 811 State Tower Bldg., Syracuse, N.Y., for the petitioners. Bernard R. Baker, III, for the respondent.


Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:

                                             Addition to
                                              Tax Under
Petitioner        Year    Deficiency     Sec. 6653(b)1

O'Brien ....      1966    $4,330.32           $2,165.16
                  1967    ...

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