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ESTATE OF BROCK v. COMMISSIONER

Docket No. 1570-77.

71 T.C. 901 (1979)

ESTATE OF FRED A. BROCK, JR., ELEANOR BROCK ILFREY, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 27, 1979.

Attorney(s) appearing for the Case

Leland B. Kee, for the petitioner.

William D. Peltz, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax of $36,490.28. The only issue presented is whether the decedent's estate is entitled to a charitable deduction under section 20551 for a gift to a church of a nontrust remainder interest in a salt royalty where an intervening life interest in the salt royalty was devised free of trust...

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