Estate of Charles Whittaker Wright, Deceased, Valerie Wright-Ballin, Administratrix, and Betty J. Wright, Deceased - Page 2




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          section 104(a)(2).1  We find that respondent’s determination was            
          in error regarding $1,257,500 of the amount in dispute.                     
                                  FINDINGS OF FACT                                    
               Petitioners were married and filed a joint Federal income              
          tax return for 1992.  Respondent issued a notice of deficiency to           
          petitioners on October 10, 1996.  Petitioners timely petitioned             
          this Court.  At the time they filed the petition, petitioners               
          resided in Los Angeles, California.                                         
               Mr. Wright died on January 1, 1999, at the age of 78.  Mrs.            
          Wright had died on January 1, 1998.  Their daughter was appointed           
          as the administratrix of her parents’ estates by the Superior               
          Court of California for the County of Los Angeles.                          
               In the mid-1960s, Mr. Wright organized Marvin Engineering              
          Co., Inc. (MEC), a California corporation, with Marvin Gussman              
          and Gerald Friedman.  MEC’s primary business was making parts for           
          the aerospace and defense industries.  Mr. Gussman served as the            
          president and chief executive officer, and Mr. Friedman served as           
          the chief financial officer.  Mr. Wright was an engineer for MEC            
          and worked in production and the development of new products.               
          Mr. Wright was also a director of MEC.                                      




               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  





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