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ESTATE OF FORTUGNO v. COMMISSIONER

Docket Nos. 69030, 69031.

24 T.C.M. 646 (1965)

T.C. Memo. 1965-124

Estate of Daniel Fortugno, Deceased, Connie M. Fortugno, Executrix, v. Commissioner. Estate of Daniel P. Fortugno, Deceased, Connie M. Fortugno, Executrix, and Connie M. Fortugno, Surviving Spouse v. Commissioner.

United States Tax Court.

Filed May 10, 1965.

Attorney(s) appearing for the Case

John J. Gibbons, for the petitioners. Francis X. Gallagher and Scott A. Dahlquist, for the respondent.

Memorandum Opinion

FAY, Judge:

The respondent determined that petitioners were liable for deficiencies in income tax and additions to tax under sections 291(a), 293(b), and 294(d)(2) of the Internal Revenue Code of 1939 and corresponding prior statutes, for various years extending from 1934 to 1950. The parties have disposed of all issues regarding the deficiencies and are in agreement that the petitioners...

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