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ESTATE OF LUTON v. COMMISSIONER

Docket No. 23339-91.

68 T.C.M. 1044 (1994)

T.C. Memo. 1994-539

Estate of William F. Luton, Deceased, Nancy L. Jackson, Robert S. Herdman, and William F. Luton, Jr., Co-Executors v. Commissioner.

United States Tax Court.

Filed October 27, 1994.

Attorney(s) appearing for the Case

Richard J. Sideman and Wendy Abkin, One Embarcadero Center, San Francisco, Calif., for the petitioner. Cynthia K. Hustad and Mary E. Wynne, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Petitioner is the Estate of William F. Luton. Respondent determined a deficiency of $7,212,448 in petitioner's estate tax. Respondent also determined that petitioner was liable for an addition to tax for negligence under section 6653(a)(1)(A) in the amount of $360,622, plus 50 percent of the interest due on the deficiency under section 6653(a)(1)(B), and was liable for an addition to tax of $1,095,102...

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