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ESTATE OF YOUNG v. COMMISSIONER

Docket No. 20139-94.

110 T.C. 297 (1998)

ESTATE OF WAYNE-CHI YOUNG, DECEASED, TSAI-HSIU HSU YANG, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 11, 1998.

Attorney(s) appearing for the Case

Lance M. Weagant and Randall D. Fowler, for petitioner.

Dwight M. Montgomery, for respondent.

WRIGHT, Judge:

Respondent determined a deficiency of $154,545 in petitioner's Federal estate tax and an addition to tax under section 6651(a)1 in the amount of $38,636. After concessions by the parties, the issues remaining are:

(1) Whether decedent's property interest in the Young property was an interest in joint tenancy or in community property. We hold that decedent held the property in joint tenancy;

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