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LYONS v. COMMISSIONER

Docket No. 6353-74.

35 T.C.M. 605 (1976)

T.C. Memo. 1976-136

Estate of John P. Lyons, Amelia R. Lyons, Administratrix, v. Commissioner.

United States Tax Court.

Filed April 29, 1976.

Attorney(s) appearing for the Case

Robert B. Milgroom, 100 Federal, Boston, Mass., for the petitioner. Jack R. Selzer, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in the estate tax of the estate of John P. Lyons in the amount of $40,747.94 and an addition to tax under section 6651 (a), I.R.C. 1954,1 in the amount of $10,186.99. The issues for decision are (1) whether respondent's determination as set forth in his notice of deficiency dated April 25, 1974, is arbitrary so as to place on respondent the...

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