T.C. Memo. 2002-238
UNITED STATES TAX COURT
ESTATE OF MARION P. BRADFORD, DECEASED,
LIZETTE L. PRYOR, EXECUTRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4659-00. Filed September 23, 2002.
Shaun A. Ingersoll, for petitioner.
Edwina L. Charlemagne, for respondent.
MEMORANDUM OPINION
WHALEN, Judge: Respondent determined a deficiency
of $294,712.16 and an addition to tax under section
6651(a)(1) of $14,736 in the Federal estate tax of the
Estate of Marion P. Bradford, Deceased. Hereinafter we
refer to Marion P. Bradford as the decedent. After
concessions, the sole issue for redetermination is the
amount of the charitable deduction under section 2055(a) of
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