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ESTATE OF MEHRAFSAR v. COMMISSIONER

Docket No. 1062-93.

72 T.C.M. 296 (1996)

T.C. Memo. 1996-351

Estate of Houshang Mehrafsar, Deceased, Bank of America, NT & SA, Special Administrator v. Commissioner.

United States Tax Court.

Filed July 31, 1996.

Attorney(s) appearing for the Case

Hugh J. Snow, for the petitioner. Nancy C. McCurley, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $1,227,639. Respondent further determined that petitioner is liable for an addition to tax for late filing of the estate tax return in the amount of $306,910. After concessions, the sole issue for decision is whether petitioner is liable for the previously mentioned addition to

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