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ESTATE OF SMITH v. COMMISSIONER

Docket Nos. 19200-94, 3976-95.

108 T.C. 412 (1997)

ESTATE OF ALGERINE ALLEN SMITH, DECEASED, JAMES ALLEN SMITH EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 4, 1997.

Attorney(s) appearing for the Case

Michael C. Riddle and Harold A. Chamberlain, for petitioner.

Carol Bingham McClure, for respondent.

OPINION

RUWE, Judge:

In docket No. 19200-94, respondent determined an estate tax deficiency of $663,785 and an accuracy-related penalty under section 6662(a)1 in the amount of $132,785.2 In docket No. 3976-95, respondent determined a deficiency of $558,272 in petitioner's Federal income tax for 1992. The deficiency determined in docket No. 3976-95 represents an alternative position taken by...

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