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ESTATE OF RODRIGUEZ v. COMMISSIONER

Docket No. 46423-86, 48430-86, 20276-87.

56 T.C.M. 1033 (1989)

T.C. Memo. 1989-13

Estate of Ruben Rodriguez, Deceased, Zoila P. Rodriguez, person in possession and administratrix, et al. v. Commissioner.

United States Tax Court.

Filed January 10, 1989.

Attorney(s) appearing for the Case

William E. Frantz and Donald B. DeLoach, 3390 Peachtree Rd. N.E., Atlanta, Ga. for the petitioners. John B. Grattan, 3390 Peachtree Rd. N.E., Atlanta, Ga., for the petitioners in Docket Nos. 48430-86 and 20276-87 only. Julie M. T. Foster, for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

In these consolidated cases the Commissioner determined a deficiency of $215,208 in Federal estate tax due from the estate of Ruben Rodriguez.

The Commissioner also determined a deficiency in petitioners' Federal income tax of $128,903.67 for the taxable year 1982 and an addition to tax of $12,890.37 pursuant to section 6661.

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