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ESTATE OF KROCK v. COMMISSIONER

Docket Nos. 6935-73, 1097-74.

46 T.C.M. 1330 (1983)

T.C. Memo. 1983-551

Estate of Miriam Krock, deceased, Nancy Dusty, Executrix v. Commissioner.

United States Tax Court.

Filed September 8, 1983.

Attorney(s) appearing for the Case

Kennard I. Mandell and Harold Brown, 66 Long Wharf, Boston, Mass., for the petitioner. Charles W. Maurer, Jr., and Willard J. Frank, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in excess of $2,200,000 in the Federal income tax of Edward and Miriam Krock for 1964 through 1969. Respondent also initially determined that Mr. and Mrs. Krock were liable for section 6653(b)1 additions to tax, but has conceded that Mrs. Krock is not liable for these additions. The issue, severed for separate trial, is whether Edward...

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