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ESTATE OF BRADLEY v. COMMISSIONER

Docket No. 4375-72.

33 T.C.M. 70 (1974)

T.C. Memo. 1974-17

Estate of Norma S. Bradley, deceased, Joseph L. Arnold and Douglas S. Bradley, Co-executors v. Commissioner.

United States Tax Court.

Filed January 24, 1974.

Attorney(s) appearing for the Case

Joseph L. Arnold, 1304 First National Bank Bldg., Lexington, Ky., for the petitioner. Christopher D. Rhodes, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in estate tax liability in the amount of $10,586.04 and an addition to tax under section 6651 (a)1 in the amount of $3,962.50. The issues for decision are as follows:

(1) Whether an election to value the property included in the decedent's gross estate, made in a delinquent estate tax return, was timely within the meaning of...

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