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ESTATE OF KELLY v. COMMISSIONER OF INTERNAL REVENUE

No. 24783-08.

T.C. Memo. 2012-73

ESTATE OF BEATRICE KELLY, DECEASED, BETTY K. WYATT, WILLIAM T. KELLY, CLAUDIA K. CANTRELL, EXECUTORS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 19, 2012.

Attorney(s) appearing for the Case

Vivian D. Hoard , for petitioner.

John T. Arthur , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge.

The issue for decision is whether the value of assets is includable in decedent's gross estate pursuant to section 2036(a).1

FINDINGS OF FACT

In 1946 Beatrice Kelly (decedent) and her husband opened a quarry in Rabun Gap, Georgia. Decedent and her husband had four children: William "Bill" Kelly, Betty Wyatt, Claudia Cantrell, and Roy...

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