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ESTATE OF CIDULKA v. COMMISSIONER

Docket Nos. 22456-91, 564-93.

71 T.C.M. 2555 (1996)

T.C. Memo. 1996-149

Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator v. Commissioner.

United States Tax Court.

Filed March 25, 1996.

Attorney(s) appearing for the Case

Joel Yonover, Brantley H. Wright, and Richard O. Kissel II, Indianapolis, Ind., for the petitioner. Stewart T. Hittinger and Russell Pinkerton, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SCOTT, Judge:

Respondent in Docket No. 22456-91 determined a deficiency in the estate tax of the Estate of Joseph Cidulka, deceased (decedent), in the amount of $1,223,726, and in Docket No. 564-93 determined a deficiency in gift taxes of decedent and additions to tax for the calendar year 1982 as follows:

                                                           Additions to Tax
             ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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