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ESTATE OF HOOVER v. COMMISSIONER

Docket No. 18464-92.

102 T.C. 777 (1994)

ESTATE OF CLARA K. HOOVER, DECEASED, YETTA HOOVER BIDEGAIN, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 21, 1994.

Attorney(s) appearing for the Case

John S. Campbell, for petitioner.

Pamelya P. Herndon, for respondent.

OPINION

RAUM, Judge:

Petitioner is the Estate of Clara K. Hoover (Mrs. Hoover), who died on March 7, 1988. The Commissioner determined a gift tax deficiency of $13,960 for the tax year ended December 31, 1987, which has been conceded in full by the Commissioner on brief, and an estate tax deficiency of $994,498, together with a section 66601 addition to estate tax in the amount of $52,391.2

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