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ESTATE OF COLE v. COMMISSIONER

Docket Nos. 362-70, 5664-74.

58 T.C.M. 715 (1989)

T.C. Memo. 1989-623

Estate of Nathaniel Cole, Deceased, Maria Cole, Executrix v. Commissioner. Gary M. Devore v. Commissioner.

United States Tax Court.

Filed November 20, 1989.

Attorney(s) appearing for the Case

Leo Branton, Jr., for the petitioner. Erik P. Doerring and Ann M. Murphy, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:*

Respondent determined a deficiency of $2,338,591.05 in the Federal estate tax of the estate of Nathaniel Cole and determined a deficiency in Gary M. Devore's Federal income tax of $135,302 and an addition to tax of $6,765 under section 6653(a)1 for the calendar year 1970.

Many of the issues raised by the pleadings have been disposed of...

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