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ESTATE OF PAXTON v. COMMISSIONER

Docket Nos. 5044-82, 17718-83, 17728-83.

86 T.C. 785 (1986)

ESTATE OF FLOYD G. PAXTON, JERRE PAXTON, PERSONAL REPRESENTATIVE; F.G. PAXTON FAMILY ORGANIZATION TRUST, JERRE PAXTON, TRUSTEE; INTERNATIONAL DEVELOPMENT TRUST, JERRE PAXTON, TRUSTEE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 28, 1986.

Attorney(s) appearing for the Case

Leon C. Misterek, George M. Hartung, Meade Emory, and Woolvin Patten, for the petitioners.

Wayne R. Appleman and Peter R. Hochman, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $11,738,717 in the estate tax for the estate of Floyd G. Paxton and an addition to tax under section 6651(a)(1)2 in the amount of $2,934,679. Also, respondent determined that the trustees of two trusts, the F.G. Paxton Family Organization Trust and the International Development Trust, are liable as transferees for the estate tax and additions to tax under sections...

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