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ESTATE OF SOBOTA v. COMMISSIONER

Docket No. 11158-94.

71 T.C.M. 3217 (1996)

T.C. Memo. 1996-294

Estate of John T. Sobota, Deceased, T.J. Sobota, Personal Representative v. Commissioner.

United States Tax Court.

Filed June 25, 1996.

Attorney(s) appearing for the Case

T.J. Sobota, for the petitioner. J. Paul Knap and Mark J. Miller, for the respondent.

MEMORANDUM OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $158,064 in petitioner's Federal estate tax. The sole issue for decision is whether the amount of the marital deduction under section 20561 must be reduced to take into account the fee of the personal representative.

The facts are fully stipulated. The stipulation of facts and attached exhibits...

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