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ESTATE OF McKELVEY v. COMMISSIONER

Docket No. 26830-14.

148 T.C. 312 (2017)

148 T.C. No. 13

ESTATE OF ANDREW J. McKELVEY, DECEASED, BRADFORD G. PETERS, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 19, 2017.

Attorney(s) appearing for the Case

Robert A. Rudnick , Kristen M. Garry , and Mark D. Lanpher , for petitioner.

Steven N. Balahtsis and Steven A. Sirotic , for respondent.

OPINION

Respondent determined a $41,257,103 deficiency in Andrew J. McKelvey's (decedent) 2008 Federal income tax. The only issue for decision is whether modifications made in 2008 to decedent's variable prepaid forward contracts (VPFC) resulted in taxable exchanges pursuant to section 1001.1<...

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