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ESTATE OF GORE v. COMMISSIONER

Dkt. Nos. 467-02, 468-02.

93 T.C.M. 1436 (2007)

T.C. Memo. 2007-169

Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Sylvia Gore, Deceased, Pamela Powell, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

June 27, 2007.

Attorney(s) appearing for the Case

Paul R. Hodgson and James E. Poe, for petitioner.

Elizabeth Downs, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency of $1,071,650 in the Federal estate tax of the Estate of Sylvia Gore (the estate).1 By separate notice of deficiency, respondent determined a Federal gift tax deficiency of $918,962 with respect to Sylvia Gore's 1997 taxable year. The personal representative of the estate filed separate petitions to redetermine the deficiencies of the estate...

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