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ESTATE OF BENNETT v. COMMISSIONER

Docket Nos. 22432-87, 22433-87.

58 T.C.M. 1056 (1989)

T.C. Memo. 1989-681

Estate of Joseph G. Bennett, Deceased, Ruby L. Bennett and Michael W. Bennett, Administrators v. Commissioner. Ruby L. Bennett v. Commissioner.

United States Tax Court.

Filed December 28, 1989.

Attorney(s) appearing for the Case

James J. Conroy III, 10370 Main St., Fairfax, Va., for the petitioners. Ruud L. Duvall, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined deficiencies for the calendar year 1983 in petitioner Estate of Joseph G. Bennett's Federal gift tax in the amount of $104,546.44 and in petitioner Ruby L. Bennett's Federal gift tax in the amount of $104,546.44.

The issues for our consideration are (1) whether respondent is equitably estopped from asserting any deficiency in the Federal gift tax of petitioner Ruby L. Bennett...

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