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ESTATE OF SWALLEN v. COMMISSIONER

Docket No. 10296-91.

65 T.C.M. 2332 (1993)

T.C. Memo. 1993-149

Estate of Coyla Burnell Swallen, Deceased, S. Paul Mathews and Robert A. Davis, Co-Executors v. Commissioner.

United States Tax Court.

Filed April 6, 1993.

Attorney(s) appearing for the Case

Thomas C. Rink, Cynthia A. Fazio, 201 E. Fifth St., Cincinnati, Ohio, for the petitioner. Jeffrey L. Bassin, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Chief Judge:

Respondent determined a deficiency of $741,689 in petitioner's Federal estate tax. In addition, respondent determined deficiencies in petitioner's Federal gift tax for the taxable years 1986 and 1987 in the amounts of $47,150 and $99,746, respectively.

This case is before the Court on the parties' cross-motions for partial summary judgment pursuant...

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