ESTATE OF KIRKPATRICK v. COMMISSIONER

Docket No. 35715-87.

61 T.C.M. 2147 (1991)

T.C. Memo. 1991-110

Estate of J.W. Kirkpatrick, Deceased, Scott Kirkpatrick, Executor, and Julia Kirkpatrick v. Commissioner.

United States Tax Court.

Filed March 14, 1991.


Attorney(s) appearing for the Case

Thompson Kirkpatrick, for the petitioners. Edsel Ford Holman, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In separate notices of deficiency dated July 29, 1987, respondent determined deficiencies in petitioners' Federal income tax for 1979 and 1980 as follows:

Year                             Deficiency

1979 ........................   $134,641.89
1980 ........................   $  2,990.76

Respondent has conceded the deficiency determined for 1980 with respect to...

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