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ESTATE OF PRINCE v. COMMISSIONER

Docket No. 21309-89.

61 T.C.M. 2594 (1991)

T.C. Memo. 1991-208

Estate of Myrtle S. Levin Prince, Deceased, Marc Alan Levin, Executor v. Commissioner.

United States Tax Court.

Filed May 14, 1991.

Attorney(s) appearing for the Case

Larry J. White, 1126 Ponce de Leon Ave., N.E., Atlanta, Ga., and Marc Alan Levin, 6400 Powers Ferry Road, N.W., Atlanta, Ga., for the petitioner.

Willard N. Timm, Jr., for the respondent.

Memorandum Opinion

TANNENWALD, Judge.

Respondent determined an estate tax deficiency of $482,700.40, based in part on the omission of certain gifts for estate tax purposes, and an addition to tax of $131,686.00 under section 6660.1 After concessions, the sole remaining issue for decision is whether respondent may include such omitted gifts made in a year which is closed to the assessment of any gift tax under section 6501 when...

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