United States Tax Court April 16, 1990, Docket No. 37702-87 (Estate of Bowers v. Commissioner)

lead-opinion

OPINION

Raum, Judge:

Petitioner is the Estate of Alexander S. Bowers. The Commissioner determined deficiencies in the decedent’s income tax for the calendar years 1982 and 1983 in the amounts of $43,211.42 and $216,851, respectively. The decedent was a resident of Virginia, and Robert M.