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ESTATE OF RICHARD v. COMMISSIONER

Docket No. 1837-75.

35 T.C.M. 530 (1976)

T.C. Memo. 1976-117

Estate of Richard H. Rackett, Robert C. Finley, Executor v. Commissioner.

United States Tax Court.

Filed April 19, 1976.

Attorney(s) appearing for the Case

David R. Calvert, for the petitioner. Jeff P. Ehrlich, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $2,267.52 in the Federal estate tax of petitioner and, under section 6651(a) (1), Internal Revenue Code of 1954, as amended,1 an addition to tax of $566.80.

We must decide (1) if the value of petitioner's assets as determined upon audit was excessive; (2) if the addition to tax in the amount of $566.80 was determined arbitrarily...

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