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ESTATE OF HAYDEL v. COMMISSIONER

Docket No. 2901-88.

62 T.C.M. 956 (1991)

T.C. Memo. 1991-507

Estate of Adam R. Haydel, Sr., Cecilia Robert, Testamentary Executrix v. Commissioner.

United States Tax Court.

Filed October 7, 1991.

Attorney(s) appearing for the Case

Vallerie Oxner, 4480 General DeGaulle, New Orleans, La., for the petitioner.

Joseph Ineich, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In a deficiency notice dated November 17, 1987, respondent determined a deficiency in the Federal estate tax of the Estate of Adam R. Haydel, Sr. (petitioner), in the amount of $653,280 and an addition to tax of $155,918 under section 6651(a)(1).1

After concessions,2 the issues for decision are: (1) Whether during his lifetime Adam R...

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