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JOHNSON v. COMMISSIONER

Docket No. 20477-96.

78 T.C.M. 358 (1999)

T.C. Memo. 1999-284

Estate of Florence H. Devida Johnson, Deceased, Richard B. Perlman, Executor v. Commissioner.

United States Tax Court.

Filed August 27, 1999.

Attorney(s) appearing for the Case

Richard B. Perlman, Longboat Key, Fla., for the petitioner. Robert W. Dillard, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

The parties submitted this case to the Court without trial. See Rule 122. Respondent determined that Florence H. DeVida Johnson (Ms. Johnson) is personally liable as a fiduciary for disbursements she made while acting as personal representative of the estate of Samuel C. Johnson III (Mr. Johnson). Respondent issued a notice of liability to the Estate of Florence H. DeVida Johnson (petitioner) on June 25, 1996.

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