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ESTATE OF SAUNDERS v. COMMISSIONER

Docket No. 10957-09.

136 T.C. 406 (2011)

ESTATE OF GERTRUDE H. SAUNDERS, DECEASED, WILLIAM W. SAUNDERS, JR., AND RICHARD B. RIEGELS, CO-EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 28, 2011.

Attorney(s) appearing for the Case

Thomas F. Carlucci, for petitioner.

Andrew R. Moore and Shannon Edelstone, for respondent.

OPINION

COHEN, Judge:

Respondent determined a deficiency of $14,400,000 in estate tax due from the Estate of Gertrude H. Saunders (decedent). Respondent also determined a penalty under section 6662(h) of $5,760,000, but that penalty has now been conceded. The case is before the Court for a preliminary determination of whether a claim against the estate satisfies the requirements of section 20.2053-1(b)(3...

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