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ESTATE OF NORDQUIST v. COMMISSIONER

Docket No. 4146-70.

31 T.C.M. 994 (1972)

T.C. Memo. 1972-198

Estate of Oscar A. Nordquist, Deceased, Georgiana G. Nordquist, Executrix, and Georgiana G. Nordquist v. Commissioner.

United States Tax Court.

Filed September 11, 1972.

Attorney(s) appearing for the Case

John H. Perkins, Jr., Michael J. Close, and Bruce A. Ackerman, 140 Broadway, New York, N.Y., for the petitioners. Michael K. Phalin, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

In this proceeding, the Commissioner determined a deficiency in Federal income tax against the petitioners for the year 1965 in the amount of $2,569.60, together with an addition to the underpayment of tax for negligence pursuant to section 6653(a).1 The petitioners have conceded the addition to the tax under section 6653(a). The sole question for decision is whether the...

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