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ESTATE OF EDDY v. COMMISSIONER

Docket No. 2735-99.

115 T.C. 135 (2000)

ESTATE OF EDWARD H. EDDY, DECEASED, NATIONAL CITY BANK, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 16, 2000.

Attorney(s) appearing for the Case

Carl Wells, for petitioner.

Carol A. Szczepanik, for respondent.

OPINION

PARR, Judge.

Respondent determined a deficiency of $421,214 in the estate's Federal estate tax and an addition to tax of $58,450 for the failure to file the estate tax return timely.

After concessions,1 the issues for decision are: (1) Whether, despite the executor's failure to make the alternate valuation election pursuant to section 2032 within 1 year after the...

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