WILLIAMSON v. COMMISSIONER

Docket No. 33059-87.

93 T.C. 242 (1989)

BERYL P. WILLIAMSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 21, 1989.


Attorney(s) appearing for the Case

Robert K. Smith and Gary E. Elam, for the petitioner.

James J. Posedel, Steven D. Blanc, and Catherine M. Brady, for the respondent.


OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $42,026 in estate tax against petitioner Beryl P. Williamson under section 2032A(c)(1).1 The deficiency was determined against petitioner in his capacity as qualified heir of Elizabeth R. Williamson (hereinafter decedent), his mother, who died on July 27, 1983.

The issue for decision is whether petitioner is liable for the additional...

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