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ESTATE OF ROGERS v. COMMISSIONER

Docket No. 23668-95.

78 T.C.M. 400 (1999)

T.C. Memo. 1999-295

Estate of William T. Rogers, Deceased, Gayle M. Rogers, Personal Representative, and Gayle M. Rogers v. Commissioner.

United States Tax Court.

Filed September 3, 1999.

Attorney(s) appearing for the Case

William T. Ramsey, for the petitioners. Clinton M. Fried, for the respondent.

MEMORANDUM OPINION

WELLS, Judge:

Respondent determined a deficiency in petitioners'1 1991 Federal income tax in the amount of $3,506,517 and a section 6662 penalty of $701,303.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

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