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ESTATE OF LEVINE v. COMMISSIONER

Docket No. 782-76.

72 T.C. 780 (1979)

ESTATE OF AARON LEVINE, DECEASED, HARVEY LEVINE, EXECUTOR, ET AL., AND ANNA LEVINE, SURVIVING WIFE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 6, 1979.

Attorney(s) appearing for the Case

Martin Rosen and Barry L. Gardiner, for the petitioners.

Rudolph J. Korbel and Joan Ronder Domike, for the respondent.

FORRESTER, Judge:

For their taxable years ended July 31, 1969 and 1970, respondent has determined deficiencies in petitioners' Federal income taxes in the respective amounts of $19,718.49 and $175,244.03. He has also determined a section 6651(a)1 addition to tax in the amount of $2,353.11 for the year 1969. Concessions having been made, the following issues remain for our decision:

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