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ESTATE OF SIMPSON v. COMMISSIONER

Docket No. 4397-92.

67 T.C.M. 3062 (1994)

T.C. Memo. 1994-259

Estate of R. Jack Simpson, Deceased, Kenneth A. Whittaker, Personal Representative v. Commissioner.

United States Tax Court.

Filed June 7, 1994.

Attorney(s) appearing for the Case

David M. Presnick, and Richard O. Jones, P.O. Box 580, Indialantic, Fla., for the petitioner. Jane T. Dickinson, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioner's estate tax in the amount of $536,140 and an addition to tax under section 6651(a)(1) in the amount of $52,228.

After concessions, the issues for decision are:

(1) Whether petitioner is entitled to a marital deduction in the amount of $504,499. We hold that it is not.

(2) Whether...

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