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ESTATE OF SEVERT v. COMMISSIONER

Docket No. 16754-96.

75 T.C.M. 1651 (1998)

T.C. Memo. 1998-34

Estate of Doris J. Severt, Deceased, Denise M. Harple, Executor v. Commissioner.

United States Tax Court.

Filed January 27, 1998.

Attorney(s) appearing for the Case

Denise M. Harple (an executrix), Columbus, Ohio, for the petitioner. Robert D. Kaiser, for the respondent.

MEMORANDUM OPINION

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in Doris J. Severt's (decedent's) Federal income tax for the year 1993 in the amount of $1,253. The issue for decision is whether respondent is estopped from assessing the deficiency in income tax.

Some of the facts have been stipulated and are so found...

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