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ESTATE OF WILBANKS v. COMMISSIONER

Docket No. 6751-88.

94 T.C. 306 (1990)

ESTATE OF KATE S. WILBANKS, DECEASED, VIRGINIA KATE NICKERSON, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 6, 1990.

Attorney(s) appearing for the Case

D. William Garrett, Jr., for the petitioner.

Larry D. Anderson, for the respondent.

OPINION

WHITAKER, Judge:

This case is before us on petitioner's motion for summary judgment, as amended, and respondent's cross-motion for summary judgment. In his notice of deficiency, respondent determined an addition to petitioner's Federal estate tax under section 6651(a)(1)1 in the amount of $54,964.86. Both parties have moved for summary adjudication in their favor on the issue of whether petitioner is liable for...

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