Estate of Frederick R. Hoffman - Page 7




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          that their $5,520 prepayment represented assessed, rather than               
          estimated, taxes.  In addition, they have conceded that the                  
          $5,520 was not due in 1996.  Accordingly, petitioners may not                
          deduct the $5,520 from their 1996 income.                                    
               Any other contention made by the parties is irrelevant,                 
          moot, or meritless.                                                          
                    To reflect the foregoing,                                          


                                                   Decision will be entered            
                                              under Rule 155.                          






























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