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additional information that decreased the estate tax liability.
See Estate of Ryan v. Commissioner, 62 T.C. 4, 10 (1974); Estate
of Archer v. Commissioner, T.C. Memo. 1984-57; sec. 20.6081-1(c),
Estate Tax Regs. Accordingly, we find the estate is liable for
the section 6651(a)(1) addition to tax as determined by
respondent.
In reaching our holdings herein, we have considered each
argument made by the parties and, to the extent not discussed
above, find those arguments to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered for
respondent.
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