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ESTATE OF NEWHOUSE v. COMMISSIONER

Docket No. 23588-83.

94 T.C. 193 (1990)

ESTATE OF SAMUEL I. NEWHOUSE, DECEASED, SAMUEL I. NEWHOUSE, JR. AND DONALD E. NEWHOUSE, EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 28, 1990.

Attorney(s) appearing for the Case

Albert H. Turkus, Judith A. Mather, James A. Treaner III, Bernard J. Long, Jr., Linda A. Fritts, and Richard L. Braunstein, for the petitioners.

Robert S. Shilliday, Jr., Albert L. Sandlin, and Howard P. Levine, for the respondent.

WILLIAMS, Judge:

The Commissioner determined a deficiency in the Federal estate tax due from the estate of Samuel I. Newhouse in the amount of $609,519,855. The Commissioner also determined an addition to tax for fraud pursuant to section 6653(b)1 in the amount of $304,759,927. The Commissioner has conceded the addition to tax for fraud.

After concessions, the remaining issues for our decision are: (1) The value, for purposes...

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