T.C. Memo. 2001-170 UNITED STATES TAX COURT ESTATE OF GLADYS J. COOK, DECEASED, VERNA LEE STEELE, EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15284-99. Filed July 9, 2001. John W. Porter, Walker Arenson, and S. Stacy Eastland, for petitioner. Lillian D. Brigman and Richard T. Cummings, for respondent. MEMORANDUM OPINION GERBER, Judge: Respondent determined a deficiency of $873,544 and a penalty under section 66621 of $168,999 in the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the date of decedent’s death, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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