T.C. Memo. 2001-235
UNITED STATES TAX COURT
ESTATE OF JAMES W. BOYLE, DECEASED, NANCY A. BOYLE AND JAMES H.
CASE, CO-PERSONAL REPRESENTATIVES AND NANCY A. BOYLE, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18586-98. Filed September 10, 2001.
David W. K. Wong, for petitioners.
Henry E. O’Neill, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: Respondent determined a deficiency of
$60,820 in the Federal income tax of petitioner Nancy A. Boyle
(Mrs. Boyle) and her deceased husband, James W. Boyle (decedent),
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