- 20 -
in the estate's gross income upon receipt by the temporary
administrator.
We have considered all other arguments made by the parties
and found them to be either irrelevant or without merit.
To reflect the foregoing,
Decision will be entered for
respondent as to the
deficiencies in tax, and in
accordance with the estate's
concession for respondent as
to the additions to tax under
section 6651(a).
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Last modified: May 25, 2011