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ESTATE OF HARTSELL v. COMMISSIONER

Docket No. 8009-03.

88 T.C.M. 267 (2004)

T.C. Memo. 2004-211

Estate of Antoinette Hartsell, Deceased, Donald C. Renbarger, Personal Representative v. Commissioner.

United States Tax Court.

September 21, 2004.

Attorney(s) appearing for the Case

Steven P. Cole, Jeff L. Todd, and Alan G. Holloway, for petitioner.

Gary L. Bloom, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of Antoinette Hartsell (estate) of $3,074,4081 and an addition to tax under section 6651(a)(2)2 for failure to pay timely. After concessions, the sole issue for decision is whether the estate is liable for the addition to tax...

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