ESTATE OF SMITH v. COMMISSIONER

Docket No. 7735-86.

57 T.C.M. 1163 (1989)

T.C. Memo. 1989-399

Estate of Kenneth F. Smith, Deceased, Edithe L. Smith, Administratrix v. Commissioner.

United States Tax Court.

Filed July 31, 1989.


Attorney(s) appearing for the Case

James T. Knight and James P. Knight, Jr., 100 S. Congress St., Jackson, Miss., for the petitioner. Marsha R. Yowell, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency of $27,922.00 in petitioner's Federal income tax for the taxable year 1981. The issues to be decided are: (1) whether the property known as Sierra Vista was community property or separate property on the date the property was sold; and (2) whether respondent waived his right to proceed against petitioner.

Findings of Fact

Some of the facts have been...

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