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ESTATE OF DeNIRO v. COMMISSIONER

Docket No. 9178-76.

44 T.C.M. 981 (1982)

T.C. Memo. 1982-497

Estate of Vincent DeNiro, Deceased, Helen M. Papalia and Joanne F. DeNicholas, Administratrices, Louis R. DeNiro, Transferee, Frank DeNiro, Transferee, and Michael DeNiro, Transferee v. Commissioner.

United States Tax Court.

Filed August 30, 1982.

Attorney(s) appearing for the Case

James C. Herndon, William T. Walker, and Robert W. Malone, 1500-I Cascade Plaza, Akron, Ohio, for the petitioners. Richard S. Bloom and Buckley D. Sowards, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency of $46,268.20 in the 1969 Federal income tax of the Estate of Vincent DeNiro and imposed an addition to tax pursuant to section 6651(a)(1)1 of $11,567.05.2 The issues for decision are:

1. Whether the payments made by two corporations to satisfy the estate tax liability assessed by respondent against the...

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