BRECKENRIDGE v. COMMISSIONER

Docket No. 8485-79.

45 T.C.M. 650 (1983)

T.C. Memo. 1983-66

Don Breckenridge and estate of Marye M. Breckenridge, deceased, Jan French, Independent Personal Representative v. Commissioner.

United States Tax Court.

Filed February 2, 1983.


Attorney(s) appearing for the Case

Edward B. Goodrich, 800 Union Bank Bldg., Grand Rapids, Mich., for the petitioners, Clyde W. Mauldin, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

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

                                Addition to Tax
  Year            Deficiency     Sec. 6653(a)1

  1972 .......    $  4,106.57     $  205.33
  1973 .......     361,937.60     18,096.88

Respondent conceded the 1972 deficiency,

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