T.C. Memo. 1996-351
UNITED STATES TAX COURT
ESTATE OF HOUSHANG MEHRAFSAR, DECEASED, BANK OF AMERICA,
NT & SA, SPECIAL ADMINISTRATOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1062-93. Filed July 31, 1996.
Hugh J. Snow, for petitioner.
Nancy C. McCurley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined a deficiency in
petitioner's Federal estate tax in the amount of $1,227,639.
Respondent further determined that petitioner is liable for an
addition to tax for late filing of the estate tax return in the
amount of $306,910. After concessions, the sole issue for
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