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ESTATE OF MACHAT v. COMMISSIONER

Docket No. 21573-96.

75 T.C.M. 2194 (1998)

T.C. Memo. 1998-154

Estate of Martin J. Machat, Deceased, Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner.

United States Tax Court.

Filed April 27, 1998.

Attorney(s) appearing for the Case

Richard S. Kestenbaum and Bernard S. Mark, for the petitioner. Janet F. Appel and Donald A. Glassel, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

The Estate of Martin J. Machat (the estate) petitioned the Court to redetermine respondent's determination of deficiencies in the amounts of $26,383 and $277,309 in its 1988 and 1989 Federal income tax, respectively, and additions thereto under section 6651(a) in the respective amounts of $6,596 and $69,327.

Following the estate's concession as to the 1988 and 1989...

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