T.C. Memo. 1996-29
UNITED STATES TAX COURT
ESTATE OF SYLVIA P. GOLDMAN, DECEASED, MARSHA GOLDBERG
AND LINDA TANENBAUM, CO-EXECUTRICES, Petitioner v. COMMISSIONER
OF INTERNAL REVENUE, Respondent
Docket No. 16970-94. Filed January 25, 1996.
Gerald N. Daffner, for petitioner.
Marcie B. Harrison and Theodore R. Leighton, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated July 11, 1994, respondent
determined a deficiency in petitioner's estate tax in the amount
of $271,031.37 and an accuracy-related penalty for negligence
under section 6662(b)(1) in the amount of $42,763.25.
After concessions, the issues before the Court are as
follows:
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