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ESTATE OF COOPER v. COMMISSIONER

Docket No. 10699-78.

74 T.C. 1373 (1980)

ESTATE OF ALBERTA D. COOPER, DECEASED, HERBERT WARREN COOPER III, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 23, 1980.

Attorney(s) appearing for the Case

Paul Jameson, for the petitioner.

Joyce H. Errecart, for the respondent.

OPINION

WILBUR, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $7,861.05. The sole issue presented here for our decision is whether the decedent retained a life estate within the meaning of section 20361 when she gave certain bonds to a trust, in 1971, but retained all of the interest coupons payable through 1979.

All of the facts have...

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