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ESTATE OF SMITH v. COMMISSIONER

Docket No. 19200-94.

123 T.C. 15 (2004)

123 T.C. No. 2

ESTATE OF ALGERINE ALLEN SMITH, DECEASED, JAMES ALLEN SMITH, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 13, 2004.

Attorney(s) appearing for the Case

Harold A. Chamberlain and Michael C. Riddle, for petitioner.

R. Scott Shieldes, for respondent.

OPINION

RUWE, Judge:

This matter is before the Court pursuant to the estate's motion for proceeding to enforce overpayment determination pursuant to Rule 260.1 Our jurisdiction to grant such relief is conferred by section 6512(b)(2).

Background

In 1994, respondent issued a notice of deficiency determining an estate tax deficiency of $663,785 and an accuracy-related penalty under section 6662(a...

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