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ESTATE OF HOFFMAN v. COMMISSIONER

Docket No. 9952-98.

78 T.C.M. 898 (1999)

T.C. Memo. 1999-395

Estate of Frederick R. Hoffman, Deceased, Marilyn C. Hoffman, Executor, and Marilyn C. Hoffman v. Commissioner.

United States Tax Court.

Filed December 6, 1999.

Attorney(s) appearing for the Case

Frank Agostino, Susan M. Flynn, and Andrew D. Engel, for the petitioners.

Craig Connell, and Francis J. Strapp, Jr., for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notice dated April 3, 1998, respondent determined deficiencies of $63,322, $76,801, and $60,804 in petitioners' 1994, 1995, and 1996 Federal income taxes, respectively.

All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues are whether petitioners: ...

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