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ESTATE OF SCHUTT v. COMMISSIONER

Dkt. No. 19208-02.

89 T.C.M. 1353 (2005)

T.C. Memo. 2005-126

Estate of Charles Porter Schutt, Deceased, Charles P. Schutt, Jr., and Henry I. Brown III, Co-Executors v. Commissioner.

United States Tax Court.

May 26, 2005.

Attorney(s) appearing for the Case

John W. Porter, W. Donald Sparks II, and Michael R. Stein, for petitioner.

Gerald A. Thorpe for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

By a statutory notice dated October 11, 2002, respondent determined a Federal estate tax deficiency in the amount of $6,113,583.03 with respect to the estate of Charles Porter Schutt (the estate). By answer, respondent asserted an increase in the deficiency of $1,409,884.65. Thereafter, by amendment to answer, respondent asserted a further increase in the deficiency of $3,595,513.32 (for a total deficiency...

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