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ESTATE OF ROSEN v. COMMISSIONER

Docket No. 18844-04.

131 T.C. 75 (2008)

ESTATE OF LEONARD ROSEN, DECEASED, BERNICE SIEGEL, SPECIAL ADMINISTRATOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 20, 2008.

Attorney(s) appearing for the Case

Michael R. Morris, for petitioner.

Louis B. Jack, for respondent.

OPINION

LARO, Judge:

This case is before the Court for decision without trial. See Rule 122.1 The Estate of Leonard Rosen, deceased (estate), Bernice Siegel, special administrator, petitioned the Court to redetermine respondent's determination of a $39,956 deficiency in Federal estate tax and a $28,968 addition thereto under section 6651(f) (or alternatively section 6651(a)(1)...

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