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ESTATE OF SMITH v. COMMISSIONER

Docket No. 8456-75.

36 T.C.M. 1770 (1977)

T.C. Memo. 1977-433

Estate of Clint M. Smith, Deceased, Donna J. Smith, Independent Executrix and Donna J. Smith v. Commissioner.

United States Tax Court.

Filed December 27, 1977.

Attorney(s) appearing for the Case

Hugh O. Mussina, 3131 Turtle Creek Blvd., Dallas, Tex., for the petitioners. Charles R. Billings, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent issued a statutory notice of deficiency on June 17, 1975 in which he determined deficiencies in, and additions to, petitioners' Federal income tax for the calendar years 1968 and 1970 as follows:

                               Addition to
  Year       Deficiency     under Sec. 6651(a)

  1968 .... $1,210,297.43     $ 60,514...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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