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ESTATE OF SCHOTT v. COMMISSIONER

Docket No. 5283-78.

43 T.C.M. 1188 (1982)

T.C. Memo. 1982-222

Estate of Harold C. Schott, Deceased, Howard J. vanden Eynden and L. Thomas Hiltz, Co-Executors v. Commissioner.

United States Tax Court.

Filed April 26, 1982.

Attorney(s) appearing for the Case

Carter Bledsoe, Thomas F. Allen, Eric M. Oakley, 1800 Union Commerce Bldg., Cleveland, Ohio, and Frederick L. Fisher, for the petitioner. Carolyn M. Parr, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in the decedent's Federal income taxes in the amount of $508,200 for the taxable year 1973 and $306,641.56 for the taxable year 1974. The respondent, in two amendments to his Answer, claimed increased deficiencies and raised additional issues and theories.

The following issues are presented for our decision:

1. To what extent, if any, did the decedent...

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