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ESTATE OF GLASSMAN v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 13533-20.

T.C. Memo. 2024-51

ESTATE OF RANDY GLASSMAN, DECEASED, STEVEN GLASSMAN, PERSONAL REPRESENTATIVE, AND STEVEN GLASSMAN, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed April 24, 2024.

Attorney(s) appearing for the Case

Michael D. Flynn , Thomas F. DiLullo , and Nicholas G. Kokis , for petitioners.

Erika B. Cormier , Marie E. Small and Marissa J. Savit , for respondent.

MEMORANDUM OPINION

With respect to petitioners' Federal income tax for 2015, the Internal Revenue Service (IRS or respondent) determined a deficiency of $494,015 and an accuracy-related penalty of $98,803. Respondent has filed a Motion for Partial Summary Judgment under Rule 121,1 requesting...

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