ESTATE OF RAPP v. COMMISSIONER

Docket No. 19107-92.

71 T.C.M. 1709 (1996)

T.C. Memo. 1996-10

Estate of Bert B. Rapp, Deceased, Richard L. Rapp, Executor v. Commissioner.

United States Tax Court.

Filed January 18, 1996.


Attorney(s) appearing for the Case

Dennis N. Brager and Gerald E. Lunn, Jr., Los Angeles, Calif., for the petitioner. Clifton B. Cates III and Nancy C. McCurley, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

WHALEN, Judge:

Respondent determined the following deficiency in, and additions to, petitioner's Federal estate tax:

                              Additions to Tax
                     ----------------------------------
                         Sec.

Deficiency           6653(a)(1)(A)   Sec. 6653(a)(1)(B)

                                     50% interest on:
$1...

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