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ESTATE OF HILLGREN v. COMMISSIONER

Docket No. 13394-01.

87 T.C.M. 1008 (2004)

T.C. Memo. 2004-46

Estate of Lea K. Hillgren, Deceased, Mark Hillgren, Executor v. Commissioner.

United States Tax Court.

Filed March 3, 2004.

Attorney(s) appearing for the Case

Paul Frederic Marx, for the petitioner.

Thomas J. Fernandez, Hieu C. Nguyen, Edwin Herrera, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge.

Respondent determined a deficiency of $1,269,498 in the Federal estate tax of the estate of Lea K. Hillgren (decedent), Mark Hillgren, executor, and an accuracy-related penalty under section 6662(a) of $247,691. After concessions by the parties, the issues for decision are: (1) Whether an entity entitled "The Lea K. Hillgren Partnership, A California Limited Partnership" (LKHP or partnership) is a partnership...

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