T.C. Memo. 1998-308
UNITED STATES TAX COURT
ESTATE OF ALBERT FRATINI, DECEASED, MARION FRIEDEBERG, PERSONAL
REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,
Respondent
Docket No. 18921-96. Filed August 24, 1998.
Nickolas P. Tooliatos II, for petitioner.
Allan D. Hill, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined a deficiency of $443,960
in petitioner's Federal estate tax. After concessions, the
issues remaining for decision are: (1) To what extent, if any,
did Ms. Friedeberg contribute toward the purchase of various real
properties, bank accounts, and certificates of deposit that were
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