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ESTATE OF SILVERMAN v. COMMISSIONER

Docket No. 6741-70.

61 T.C. 338 (1973)

ESTATE OF MORRIS R. SILVERMAN, AVRUM SILVERMAN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 6, 1973.

Attorney(s) appearing for the Case

Moses M. Cohen, for the petitioner.

Marion L. Westen, for the respondent.

STERRETT, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $2,155.01. However, $132.08 of said amount was attributable to the assessment of the penalty imposed by section 6651(a), I.R.C. 1954,1 which was abated, leaving a net deficiency of $2,022.93. Respondent subsequently conceded the deductibility of certain legal expenses, leaving the following...

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