ESTATE OF WILBANKS v. COMMISSIONER

Docket No. 6751-88.

61 T.C.M. 1779 (1991)

T.C. Memo. 1991-45

Estate of Kate S. Wilbanks, Deceased, Virginia Kate Nickerson, Personal Representative v. Commissioner.

United States Tax Court.

Filed February 6, 1991.


Attorney(s) appearing for the Case

D. William Garrett, Jr., for the petitioner. Larry D. Anderson, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

After resolving the underlying issues concerning petitioner's Federal estate tax, respondent issued a notice of deficiency determining an addition to tax under section 6651(a)(1)1 in the amount of $54,964.86, which is the only issue to be decided. We hold that the estate is liable for the addition.

Findings of Fact

In our two prior opinions in this case...

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