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ESTATE OF LEVIN v. COMMISSIONER

Docket Nos. 38005-84, 38006-84.

90 T.C. 723 (1988)

ESTATE OF STANTON A. LEVIN, DECEASED, INDUSTRIAL VALLEY BANK AND TRUST CO., CAROLINE LEVIN AND MERVIN J. HARTMAN, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 19, 1988.

Attorney(s) appearing for the Case

John M. Bernard and David Schechtman, for the petitioner.

Alan E. Cobb, for the respondent.

JACOBS, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $97,761.14. In addition, respondent determined a gift tax deficiency in the amount of $11,433.56 for the calendar quarter ended December 31, 1980, and an addition to tax pursuant to section 6651(a)(1)1 in the amount of $2,858.39. The deficiencies are premised on the theory that Stanton A. Levin (the decedent) made an inter vivos...

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