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ESTATE OF DAILEY v. COMMISSIONER

Docket Nos. 6251-00, 6262-00.

82 T.C.M. 710 (2001)

T.C. Memo. 2001-263

Estate of Elma Middleton Dailey, Deceased, Donor, K. Robert Dailey II, Executor v. Commissioner. Estate of Elma Middleton Dailey, Deceased, K. Robert Dailey II, Executor v. Commissioner.

United States Tax Court.

Filed October 3, 2001.

Attorney(s) appearing for the Case

Harold A. Chamberlain and Michael C. Riddle, for the petitioners. Richard T. Cummings, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notices dated March 15, 2000, respondent determined a 1992 Federal gift tax deficiency of $53,808 and section 6651(a) addition to tax of $13,452 relating to Docket No. 6251-00, and a Federal estate tax deficiency of $143,932 relating to Docket No. 6262-00. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended...

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