ESTATE OF DILLINGHAM v. COMMISSIONER

Docket Nos. 22368-85, 22369-85.

88 T.C. 1569 (1987)

ESTATE OF ELIZABETH C. DILLINGHAM, DECEASED, DAN L. DILLINGHAM AND TOM B. DILLINGHAM, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 25, 1987.


Attorney(s) appearing for the Case

Julian P. Kornfeld, Clarke L. Randall, and Kristen G. Juras, for the petitioner.

David G. Hendricks, for the respondent.


OPINION

WELLS, Judge:*

Respondent determined a deficiency in petitioner's Federal gift tax for the calendar quarter ended December 31, 1980, in the amount of $70,841.04, and an addition to tax pursuant to section 6651(a)1 in the amount of $17,710.26. Respondent also determined a deficiency in petitioner's Federal estate tax in the amount of $369,644...

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