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ESTATE OF OLIVO v. COMMISSIONER OF INTERNAL REVENUE

No. 15428-07.

T.C. Memo. 2011-163

ESTATE OF EMILIA W. OLIVO, DECEASED, ANTHONY M. OLIVO, ADMINISTRATOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 11, 2011.

Attorney(s) appearing for the Case

John R. Crayton , for petitioner.

Kristina L. Rico , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge.

Respondent determined a deficiency in the Federal estate tax of the Estate of Emilia W. Olivo (the estate) of $348,852.05 and a penalty of $13,309.29 pursuant to section 6662(g).1 After concessions, the issues we must decide are: (1) Whether the estate is entitled to deduct as an expense the claim on the estate tax return for services rendered by Anthony M. Olivo (Mr. Olivo...

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