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ESTATE OF HOLLAND v. COMMISSIONER

Docket No. 7397-94.

73 T.C.M. 3236 (1997)

T.C. Memo. 1997-302

Estate of Carolyn W. Holland, Deceased, Jack K. Holland, Lewis G. Holland, Sr., and Betty H. Kann, Executors v. Commissioner.

United States Tax Court.

Filed June 30, 1997.

Attorney(s) appearing for the Case

S. Jarvin Levison, Atlanta, Ga., for the petitioner. Clinton M. Fried, for the respondent.

MEMORANDUM OPINION

PARR, Judge:

Respondent determined a deficiency of $388,074 in the Federal estate tax of Carolyn W. Holland (decedent), who died on November 25, 1989. Respondent also determined an accuracy-related penalty of $77,615 pursuant to section 6662.1

After concessions,2 the issues for decision are: (1) Whether decedent transferred the life estate she held in a house when she attempted...

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