T.C. Memo. 1999-76
UNITED STATES TAX COURT
ESTATE OF WILLIAM J. DESMOND, DECEASED,
DONN KEMBLE, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26237-96. Filed March 10, 1999.
Donn Kemble, for petitioner.
Jeffrey A. Schlei and Michael H. Salama, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$1,055,053 in, and a section 6662(b)(1) penalty of $211,011 on,
the Federal estate tax of the estate of decedent William J.
Desmond.1
1 All section references are to the Internal Revenue Code
in effect at the date of decedent's death, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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