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ESTATE OF JOHNSON v. COMMISSIONER

Docket No. 18799-85.

88 T.C. 225 (1987)

ESTATE OF KEITH WOLD JOHNSON, DECEASED, SEYMOUR M. KLEIN, BETTY W. JOHNSON, AND ROBERT J. MORTIMER, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 29, 1987.

Attorney(s) appearing for the Case

Milton Gould and Allan Parker, for the petitioner.

Lawrence Blaskopf and John Becker, for the respondent.

WILLIAMS, Judge:

The Commissioner determined deficiencies in petitioner's Federal income tax for the taxable years 1980 and 1981 as follows:

Year                             Deficiency

1980 ...........................  $269,963
1981 ...........................   109,165

Petitioner claims an overpayment in Federal income tax in the amounts of $712,045 for 1980 and $93,198 for...

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