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ESTATE OF MACELHENNY v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 12981-19, 12982-19.

T.C. Memo. 2023-33

ESTATE OF BERNARD J. MACELHENNY, JR., DECEASED, DONOR, MICHAEL P. MACELHENNY AND CATHERINE MACELHENNY DANN, CO-EXECUTORS, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, ESTATE OF BERNARD J. MACELHENNY, JR., DECEASED, MICHAEL P. MACELHENNY AND CATHERINE MACELHENNY DANN, CO-EXECUTORS, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed March 15, 2023.

Attorney(s) appearing for the Case

Dennis L. Perez and Lacey E. Strachan , for petitioners.

Stephen O. Abanise , Jenny R. Casey , and Kim-Khanh Nguyen , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent determined gift tax deficiencies in the Estate of Bernard J. MacElhenny, Jr. (estate), for 2011 and 2012 of $188,000 and $3,335,609, respectively.1 Respondent also determined a $3,992,656 estate tax deficiency. The parties filed Stipulations...

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