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Dudley M. Lang and R. Wicks Stephens II, for petitioner.
Frederick J. Lockhart, Jr., for respondent.
MEMORANDUM OPINION
HALPERN, Judge: This case involves the Federal estate tax.
The decedent is Theodore C. Chemodurow (sometimes, Theodore). By
notice of deficiency dated December 1, 1999 (the notice),
respondent determined a deficiency in Federal estate tax of
$2,648,640, an addition to tax for failure to file tax return of
$132,432 under section 6651(a)(1), and an accuracy-related
penalty of $529,728 under section 6662(a). The case is before us
on respondent’s motion for partial summary judgment (the motion).
Petitioner objects.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect at the time of decedent’s death,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Background
Motion for Summary Judgment
A summary judgment is appropriate “if the pleadings, answers
to interrogatories, depositions, admissions, and any other
acceptable materials, together with the affidavits, if any, show
that there is no genuine issue as to any material fact and that a
decision may be rendered as a matter of law.” Rule 121(b). A
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