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ESTATE OF WOODARD v. COMMISSIONER

Docket Nos. 672-74, 673-74.

64 T.C. 999 (1975)

ESTATE OF RUSSELL G. WOODARD, DECEASED, ANNABELLE M. WOODARD, CHARLES B. CUMINGS AND GENESEE MERCHANTS BANK & TRUST CO., CO-EXECUTORS, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 28, 1975.

Attorney(s) appearing for the Case

L. Keith Borgerson and David R. Johnston, for the petitioners.

Peter M. Ritteman and Virginia M. Tomasulo, for the respondent.

SUPPLEMENTAL OPINION

GOFFE, Judge:

On June 23, 1975, we filed our opinion in Estate of Russell G. Woodard, 64 T.C. 457 (1975), in which we held that petitioners were entitled to a protective order to relieve them of unnecessary burden and expense in stipulating to matters we found not to be material or relevant to the issues before the Court. Our opinion was based upon petitioners' "Motion to Obtain Protective...

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