Estate of Doris J. Severt, Deceased, Denise M. Harple, Executor - Page 1

                                 T.C. Memo. 1998-34                                   


                               UNITED STATES TAX COURT                                


         ESTATE OF DORIS J. SEVERT, DECEASED, DENISE M. HARPLE, EXECUTOR,             
             Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent               


               Docket No. 16754-96.                 Filed January 27, 1998.           


               Denise M. Harple (an executrix), for petitioner.                       
               Robert D. Kaiser, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1                        
               Respondent determined a deficiency in Doris J. Severt's                
          (decedent's) Federal income tax for the year 1993 in the amount             

          1    All section references are to the Internal Revenue Code in             
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  





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