T.C. Memo. 2005-2
UNITED STATES TAX COURT
ESTATE OF HELEN M. NOBLE, DECEASED, LESLIE H. NOBLE, JR., AND
JOHN R. NOBLE, CO-PERSONAL REPRESENTATIVES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12606-01. Filed January 6, 2005.
Daniel J. Duffy, for petitioners.
J. Anthony Hoefer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine respondent’s determination of a $223,207 deficiency
in the Federal estate tax of the Estate of Helen M. Noble (the
estate) and a $50,221.57 addition to tax under section
6651(a)(1). Following concessions, we must decide the
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