ESTATE OF EINSIEDLER v. COMMISSIONER

Docket No. 4461-91.

67 T.C.M. 2647 (1994)

T.C. Memo. 1994-155

Estate of Maria J. Einsiedler, Deceased, Otto G. Einsiedler, Executor v. Commissioner.

United States Tax Court.

Filed April 13, 1994.


Attorney(s) appearing for the Case

Raymond J. Farrell, 400 W. Main St., Freehold, N.J., for the petitioner. Steven W. Ianacone, for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined a $259,651.81 deficiency in petitioner's Federal estate tax and a $64,912.95 addition to tax under section 6651(a)(1) for failure to timely file a return. Respondent also determined that petitioner improperly applied the special use valuation reduction of section 2032A. Petitioner concedes that respondent's determination regarding the special use valuation is correct and that petitioner...

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