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respondent under section 6651(a)(1).1 The $13,447.46 related to
a $53,790 deficiency in the Federal estate tax of the Estate of
Margaret Landers (the estate). The estate had paid the
deficiency before the notice of deficiency was issued. In docket
No. 5792-05L, petitioner petitioned the Court to review a
determination by respondent’s Office of Appeals (Appeals)
sustaining a lien relating to the estate’s liability for assessed
additions to tax under section 6651(a)(1) and (2). Those
assessed additions to tax related to the tax reported on the
estate’s Federal estate tax return (the estate tax return). In
docket No. 11015-05L, petitioner petitioned the Court to review a
determination by Appeals sustaining a levy proposed by respondent
to collect the just-mentioned assessed additions to tax, plus
interest.
The three cases resulting from these petitions were
consolidated for purposes of trial, briefing, and opinion. On
May 11, 2006, the Court granted the unopposed motion to amend the
petition in docket No. 5791-05 to allege that the estate overpaid
additions to its Federal estate tax and was entitled to a refund.
The amendment alleged that the estate paid $470,098.56 for which
it was not liable, consisting of: (1) A $340,070.40 addition to
tax under section 6651(a)(1) relating to the tax reported on the
1 Unless otherwise indicated, section references are to the
applicable version of the Internal Revenue Code.
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