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ESTATE OF ELKINS v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 16597-10.

140 T.C. 86 (2013)

ESTATE OF JAMES A. ELKINS, JR., DECEASED, MARGARET ELISE JOSEPH AND LESLIE KEITH SASSER, INDEPENDENT EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 11, 2013.

Attorney(s) appearing for the Case

Donald Frederick Wood , J. Graham Kenney , Harry M. Reasoner , Stacey N. Vu , and Juliana D. Hunter , for petitioners.

Warren P. Simonsen , Sharyn M. Ortega , and Susan S. Hu , for respondent.

HALPERN, Judge:

By notice of deficiency issued to petitioners (notice), respondent determined an estate tax deficiency of $9,068,265. Petitioners (Ms. Sasser and Ms. Joseph) are the coexecutors of the Estate of James A. Elkins, Jr. (estate), and are decedent's daughters. Their brother, James A. Elkins III (James III), who was also a coexecutor of the estate, died on June 10, 2010, less than a month after respondent issued the notice, and will not be replaced...

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