T.C. Memo. 1996-255
UNITED STATES TAX COURT
ESTATE OF HILDA F. CORBETT, DECEASED, MICHAEL A. SWEENEY,
ADMINISTRATOR, Petitioner v. COMMISSIONER
OF INTERNAL REVENUE, Respondent
Docket Nos. 13791-94, 13792-94. Filed June 3, 1996.
Michael A. Sweeney, for petitioner.
Terry W. Vincent, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: These cases were consolidated for trial,
briefing, and opinion. By notices dated May 11, 1994, respondent
determined a deficiency in decedent’s 1990 gift tax in the amount
of $23,029 and in petitioner’s estate tax in the amount of
$47,061. The issue before the Court is whether petitioner may
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