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ESTATE OF FELT v. COMMISSIONER

Docket Nos. 6961-78, 7079-78.

54 T.C.M. 528 (1987)

T.C. Memo. 1987-465

Estate of Elaine E. Felt, Deceased, Constance H. Felt, Jonathan S. Felt and Albert I. Edelman, Executors v. Commissioner. Irving M. Felt, Petitioner v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

Filed September 16, 1987.

Attorney(s) appearing for the Case

William Mulligan, 488 Madison Ave., New York, N.Y., for the petitioner in Docket No. 6961-78. Peter J. Rothenberg, Mark H. Alcott, Mildred Ellen Robb and Eileen S. Silvers, for the petitioner in Docket No. 7079-78. Frances J. Honecker and Roland Barral, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

In these consolidated cases, respondent determined deficiencies in petitioners' Federal income tax and additions to tax for the taxable year 1973 as follows:

                                                                           Additions to Tax
Petitioner                                     Deficiency   Sec. 6651(a)1   Sec. 6654

Elaine E...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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