T.C. Memo. 2001-109
UNITED STATES TAX COURT
ESTATE OF MARCIA P. HOFFMAN, DECEASED, ELISABETH HOFFMAN,
PERSONAL REPRESENTATIVE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8632-98. Filed May 9, 2001.
Joseph D. Edwards and Albert P. Silva, for petitioner.
Michael A. Pesavento, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined a deficiency of $930,864
in the Federal estate tax of the estate of decedent Marcia P.
Hoffman. After concessions,1 the issues for decisions are: (1)
1The notice of deficiency contained a number of adjustments
to decedent’s estate tax return. The parties have agreed to a
stipulation of settled issues which disposes of most of the
(continued...)
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