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ESTATE OF O'NAN v. COMMISSIONER

Docket No. 5803-64.

47 T.C. 648 (1967)

ESTATE OF MORRISON T. O'NAN, DECEASED, MORRISON A. O'NAN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 28, 1967.

Attorney(s) appearing for the Case

James E. Banahan, for the petitioner.

Sanford S. Neuman, for the respondent.

HOYT, Judge:

This proceeding involves an estate tax deficiency of $46,048.12. The question in issue is whether there should be included in decedent's gross estate the value of certain real estate consisting of farmlands which decedent conveyed to his wife under a property settlement agreement made at the time of the wife's filing of a suit for divorce. If that question is decided affirmatively, there is a further question as to valuation of the properties....

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