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ESTATE OF BENDER v. COMMISSIONER

Docket No. 9338-82.

86 T.C. 770 (1986)

ESTATE OF EDWARD P. BENDER, MARTHA A. BENDER, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 22, 1986.

Attorney(s) appearing for the Case

John Taylor, for the petitioner.

Edward Peduzzi, for the respondent.

PARR, Judge:*

Respondent determined a deficiency in petitioner's estate tax liability of $202,673.28.1 The issues for decision are: (1) Whether this Court has jurisdiction to determine decedent's correct estate tax liability when the determination involves examination of respondent's offset of a decedent's income tax liabilities against his income tax overpayments...

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