United States Tax Court January 13, 1993, Docket Nos. 14693-90, 17507-90, 17536-90, 17547-90, 20536-90 (Huddleston v. Commissioner)

lead-opinion

OPINION

Swift, Judge:

This matter is now before us on petitioner Albert J. Huddleston’s (petitioner)2 motion for summary judgment.

The underlying issue in these consolidated cases is the correctness of respondent’s determination that petitioner is liable as a fiduciary under section 69013 with respect to a $345,147 deficiency in the Federal estate tax of the Estate of Madeline S.