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ESTATE OF CARBERRY v. COMMISSIONER

Docket No. 27350-88.

95 T.C. 65 (1990)

ESTATE OF TIMOTHY F. CARBERRY, DECEASED, MANUFACTURER'S HANOVER TRUST CO., AND ELLA J. BRADY, F.K.A. ELLA J. CARBERRY, EXECUTORS, AND ELLA J. BRADY, F.K.A. ELLA J. CARBERRY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 16, 1990.

Attorney(s) appearing for the Case

Patrick W. Hennessey and William L. O'Conor, Jr., for the petitioners.

Scott P. Borsack, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $8,698 in Timothy F. Carberry's (decedent) and Ella J. Brady's (his wife)1 income tax for the taxable year 1967 and increased the interest rate on the underlying deficiency under section 6621(c).2 The deficiency arises in respect of a net operating loss carryback from 1970. The issues for...

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