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ESTATE OF SAUNDERS v. COMMISSIONER

Docket No. 10957-09.

136 T.C. 406 (2011)

ESTATE OF GERTRUDE H. SAUNDERS, DECEASED, WILLIAM W. SAUNDERS, JR., AND RICHARD B. RIEGELS, CO-EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 28, 2011.

Attorney(s) appearing for the Case

Thomas F. Carlucci , for petitioner.

Andrew R. Moore and Shannon Edelstone , for respondent.

OPINION

COHEN, Judge:

Respondent determined a deficiency of $14,400,000 in estate tax due from the Estate of Gertrude H. Saunders (decedent). Respondent also determined a penalty under section 6662(h) of $5,760,000, but that penalty has now been conceded. The case is before the Court for a preliminary determination of whether a claim against the estate satisfies the requirements of section 20.2053-1(b)(3...

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