ESTATE OF BEST v. COMMISSIONER

Docket No. 267-76.

76 T.C. 122 (1981)

ESTATE OF ROBERT W. BEST, DECEASED, JOHN FLEMING, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 26, 1981.


Attorney(s) appearing for the Case

William J. Cooney and Stephen E. Silver, for the petitioner.

Kimley R. Johnson and Joseph T. Chalhoub, for the respondent.


OPINION

RAUM, Judge:

The Commissioner determined the following deficiencies and additions to tax in respect of the decedent's 1970, 1971, and 1972 income taxes:

                                       Additions to tax
  Year               Deficiency    sec. 6653(b), I.R.C. 1954
  1970 ----------   $227,915.80           $113,957.90
  1971 ----------    195,577.66             97,788.83
  1972 ----------   ...

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