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ESTATE OF BARTLETT v. COMMISSIONER

Docket No. 5909-67.

54 T.C. 1590 (1970)

ESTATE OF SIDNEY F. BARTLETT, MIRIAM B. BUTTERFIELD, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 6, 1970.

Attorney(s) appearing for the Case

Michael K. Cavanaugh and John R. F. Baer, for the petitioner.

Bert L. Kahn, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency of $5,518.99 in the estate tax of petitioner. This asserted deficiency and a claimed overpayment of $3,512.72 are in dispute. In addition, petitioner has reserved the right to claim a deduction for reasonable legal fees incurred in this proceeding.

Concessions have been made by both parties. The issue presented for our decision is whether the...

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