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ESTATE OF GRACE MOUAT

Docket No. 3156-62.

23 T.C.M. 1717 (1964)

T.C. Memo. 1964-282

Estate of Grace Mouat by Malcolm P. Mouat as executor v. Commissioner.

United States Tax Court.

Filed October 27, 1964.

Attorney(s) appearing for the Case

Malcolm P. Mouat (executor), for the petitioner. Rex A. Guest, for the respondent.

Memorandum Opinion

FAY, Judge:

The Commissioner determined a deficiency of $10,461.16 in estate tax. The only issue for decision1 is whether a fractional residuary educational bequest should be computed without regard to the Federal estate tax.

All of the facts have been stipulated and are so found. Those necessary to an understanding of our inquiry are recited below.

Grace Mouat (hereinafter referred to as decedent...

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