ESTATE OF BLACK v. COMMISSIONER

Docket Nos. 23188-05, 23191-05, 23516-06.

133 T.C. 340 (2009)

ESTATE OF SAMUEL P. BLACK, JR., DECEASED, SAMUEL P. BLACK, III, EXECUTOR, ET AL., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 14, 2009.


Attorney(s) appearing for the Case

John W. Porter , J. Graham Kenney , Stephanie Loomis-Price , and Jason S. Zarin , for petitioner.

Gerald A. Thorpe and Andrew M. Stroot , for respondent.


HALPERN, Judge:

Respondent has issued four notices of deficiency (the notices) to Samuel P. Black III (petitioner). Two were issued to him in his capacity as executor of the estate of Samuel P. Black, Jr. (Mr. Black's estate and Mr. Black, respectively), and two were issued to him in his capacity as executor of the estate of Irene M. Black (Mrs. Black's estate and Mrs. Black, respectively). Two notices were with respect...

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