T.C. Memo. 2000-133
UNITED STATES TAX COURT
ESTATE OF CAROLYN J. ROGERS, DECEASED, JOHN A. ROGERS, III,
EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,
Respondent
Docket No. 2796-97. Filed April 12, 2000.
David D. Aughtry and Howard W. Neiswender, for petitioner.
Robert W. West, for respondent.
MEMORANDUM OPINION
HAMBLEN, Judge: Respondent determined a deficiency of
$305,997 in the Federal estate tax of the Estate of Carolyn J.
Rogers (decedent). After concessions by the parties,1 the issue
1The parties made the following concessions: Petitioner did
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