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ESTATE OF FOX v. COMMISSIONER

Docket No. 7025-93.

69 T.C.M. 1719 (1995)

T.C. Memo. 1995-30

Estate of Nathalie N. Fox, Deceased, Kenneth Fox, Executor v. Commissioner.

United States Tax Court.

Filed January 24, 1995.

Attorney(s) appearing for the Case

Wallace Musoff and Michael J. Coyle, 635 Madison Ave., New York, N.Y., for the petitioner. James Biagi and Paula Zimmerman, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $230,230.97 and that petitioner is liable for the fraud penalty under section 66631 in the amount of $172,673.23. Respondent alternatively asserted in the Answer that to the extent that petitioner is not found to be liable for the fraud penalty, petitioner is liable for the accuracy-related...

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