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ESTATE OF MILLER v. COMMISSIONER

Docket No. 5875-88.

62 T.C.M. 997 (1991)

T.C. Memo. 1991-515

Estate of Darwin A. Miller, Deceased, Virginia P. Miller, Testamentary Executrix and Surviving Spouse, and Virginia P. Miller v. Commissioner.

United States Tax Court.

Filed October 9, 1991.

Attorney(s) appearing for the Case

Michael E. Guarisco, 650 Poydras St., New Orleans, La., David A. Aymond, and Richard K. Leefe, for the petitioners.

Stevens E. Moore, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined the following deficiencies and additions to tax in petitioners' Federal income taxes:

                                                          Additions to Tax
Year                                         Deficiency      Sec. 66591

1981 ....................................   $820,422.00     $246,126.60
1982...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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