ESTATE OF FREEDMAN v. COMMISSIONER

Dkt. No. 6416-04.

93 T.C.M. 1007 (2007)

T.C. Memo. 2007-61

Estate of Frances Elaine Freedman, Deceased, Robin Elaine Carnette, Personal Representative v. Commissioner.

United States Tax Court.

March 19, 2007.


Attorney(s) appearing for the Case

Joe M. Gonzalez, for petitioner.

Michael A. Pesavento, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

Respondent determined a Federal income tax deficiency in the amount of $567,864 and a penalty pursuant to section 6662 of $113,572.80 with respect to the 2000 taxable year of Frances Elaine Freedman (decedent).1 After concessions, to be explained in greater detail below, the principal issue for decision is what portion of gain from certain stock sales is taxable to decedent...

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