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ESTATE OF ROBERTS v. COMMISSIONER

Docket No. 5712-70.

59 T.C. 128 (1972)

ESTATE OF MATTIE ROBERTS, DECEASED, RAY ROBERTS, INDEPENDENT EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 19, 1972.

Attorney(s) appearing for the Case

Elwood Cluck, for the petitioner.

W. Read Smith, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $45,828.99 in the estate tax of the Estate of Mattie Roberts. The only issue remaining for consideration relates to the includability and value of what will henceforth be referred to as "agency rights" allegedly owned by the decedent at the time of her death.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly.

Mattie Roberts (hereinafter referred...

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