ESTATE OF ESTROFF v. COMMISSIONER

Docket No. 17880-80.

47 T.C.M. 234 (1983)

T.C. Memo. 1983-666

Estate of Maxwell J. Estroff, Deceased, Naomi Estroff and Dale Toporek, Executrixes, and Naomi Estroff v. Commissioner.

United States Tax Court.

Filed November 3, 1983.


Attorney(s) appearing for the Case

William J. Cooney, 1104 Georgia Bank Bldg., Augusta, Ga. for the petitioners. Julian A. Fortuna, for the respondent.


Memorandum Opinion

DRENNEN, Judge:

Respondent determined deficiencies in and additions to the Federal income taxes of Maxwell J. and Naomi Estroff for the taxable years 1974 and 1975 as follows:

                                 Addition to tax1
  Year             Deficiency        sec. 6653(a)

  1974 ........... $62,568.06         $3,128.40
  1975 ...........  13,030.35            651.52

After concessions...

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