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ESTATE OF PENNEY v. COMMISSIONER

Docket No. 5399-70.

59 T.C. 102 (1972)

ESTATE OF HERBERT R. PENNEY, DECEASED, MILTON H. PENNEY, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 17, 1972.

Attorney(s) appearing for the Case

Richard R. Stedman and William W. Ellis, Jr., for the petitioner.

Ross E. Springer, for the respondent.

TIETJENS, Judge:

The Commissioner determined a deficiency of $2,392,016.62 in the estate tax liability of the estate of decedent Herbert R. Penney. Prior to the trial the estate made several concessions so that the remaining issue simply concerns the ultimate burden of the Federal estate tax liability under Ohio law.

FINDINGS OF FACT

The petitioner is the Estate of Herbert R. Penney, deceased, Milton H. Penney, executor, Defiance, Ohio. The...

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