T.C. Memo. 2005-128
UNITED STATES TAX COURT
ESTATE OF TIMOTHY J. TEHAN, DECEASED, TIMOTHY R. TEHAN, EXECUTOR,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17282-03. Filed May 31, 2005.
Michael F. Callahan, for petitioner.
William J. Gregg and Ann Welhaf, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$132,415 in Federal estate tax (estate tax) with respect to the
estate (estate) of Timothy J. Tehan (decedent).
The issues remaining for decision are:
(1) Is certain property includible in decedent’s gross
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