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ESTATE OF ZLOTOWSKI v. COMMISSIONER

Dkt. No. 22150-04.

94 T.C.M. 101 (2007)

T.C. Memo. 2007-203

Estate of Gertrude Zlotowski, Deceased, Gunther Grewe, Ancillary Administrator, C.T.A. v. Commissioner.

United States Tax Court.

July 24, 2007.

Attorney(s) appearing for the Case

Susan Litwer, Howell Bramson, and Robert H. Rosh (specially recognized), for petitioner.

Lydia A. Branche and Shawna A. Early, for respondent.

MEMORANDUM OPINION

HALPERN, Judge.

This case involves the Federal estate tax. The decedent (decedent) is Gertrude Zlotowski. By notice of deficiency dated August 24, 2004, respondent determined a deficiency in Federal estate tax of $933,437 and an addition to tax for failure to file timely the estate tax return of $233,359.

All section references are to the Internal Revenue Code in effect for the date of decedent's death, and all Rule references...

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