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ESTATE OF BROCKENBROUGH v. COMMISSIONER

Docket No. 22596-95.

76 T.C.M. 1063 (1998)

T.C. Memo. 1998-454

Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Co-Executors, and Sharon Brockenbrough v. Commissioner.

United States Tax Court.

Filed December 28, 1998.

Attorney(s) appearing for the Case

Vivian D. Hoard, David D. Aughtry, Atlanta, Ga., and Donald P. Lancaster, for the petitioners. Clinton M. Fried, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' 1991 and 1992 Federal income tax and an accuracy-related penalty as follows:

                                       Sec. 662
Year                     Deficiency     Penalty

1991 .................     $11,611    $2,322.20
1992 .................      16,818...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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