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Peter L. Milinkovich, for petitioner.
Gail K. Gibson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Estate of Irving Nemerov, Deceased,
Bernice Midgorden, Personal Representative, petitioned the Court
to redetermine respondent's determination of a deficiency in its
Federal estate tax, and additions thereto under section
6651(a)(1) and (2). Following concessions by the parties, we
must decide whether the estate is liable for the additions to tax
under section 6651(a)(1) and (2). We hold it is.
Unless otherwise stated, section references are to the
applicable provisions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
Estate references are to the Estate of Irving Nemerov. Decedent
references are to Mr. Nemerov. Commissioner references are to
the Commissioner of Internal Revenue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference. The decedent was an
attorney residing in Hennepin, Minnesota, when he died on June 8,
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