T.C. Memo. 2002-82
UNITED STATES TAX COURT
ESTATE OF EARL C. KOESTER, DECEASED, CAROL C. FORTNEY AND ROGER
D. FORTNEY, PERSONAL REPRESENTATIVES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 530-00. Filed March 28, 2002.
Roger D. Fortney, for petitioner.
George W. Bezold, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $45,241 deficiency
in estate tax for Earl C. Koester’s estate (the estate). After
a timely petition was filed, respondent conceded the $45,241
estate tax deficiency. Following this concession, the estate
argues that the $109,270 estate tax liability it originally
reported on its estate tax return was incorrect. The estate,
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