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ESTATE OF LENNON v. COMMISSIONER

Docket No. 2230-89.

62 T.C.M. 326 (1991)

T.C. Memo. 1991-360

Estate of Ann Marie Lennon, Deceased, Elizabeth L. Sachs, Personal Representative v. Commissioner.

United States Tax Court.

Filed August 5, 1991.

Attorney(s) appearing for the Case

Steven I. Weissman, 169 E. Flagler St., Miami, Fla., for the petitioner. Henry J. Riordan and Frances D. Sheehy for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

By notice of deficiency, respondent determined a deficiency of $453,673 and an addition to tax under section 6651(a)(1)1 of $118,798 in the Federal estate tax liability of decedent Ann Marie Lennon. In an amended answer, respondent increased the deficiency and the addition to tax under section 6651(a)(1) to $1,212,098 and $254,605, respectively.

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