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ESTATE OF WHITT v. C.I.R.

No. 84-7026.

751 F.2d 1548 (1985)

ESTATE OF Elbert B. WHITT, Loyd Whitt, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

February 4, 1985.

Attorney(s) appearing for the Case

J. Gilmer Blackburn, Blackburn & Maloney, Mark Daniel Maloney, Decatur, Ala., for petitioner-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Robert A. Bernstein, John A. Dudeck, Jr., Tax Division, U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before RONEY and HENDERSON, Circuit Judges, and TUTTLE, Senior Circuit Judge.

TUTTLE, Senior Circuit Judge:

This is an appeal from a judgment of the Tax Court upholding the determination of the Commissioner of Internal Revenue ("Commissioner") that there were deficiencies in federal estate and gift taxes paid by the estate of Elbert B. Whitt ("Estate").

Elbert B. Whitt, a resident of Ardmore, Limestone County, Alabama, died June 14, 1969, at the age of 82. On September 12, 1975, the executor of his estate, his son, Loyd H. Whitt, filed...

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