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ESTATE OF VRINIOTIS v. COMMISSIONER

Docket No. 11353-78.

79 T.C. 298 (1982)

ESTATE OF EFTHIMIOS D. VRINIOTIS, DECEASED, ATLANTIC BANK OF NEW YORK, ANCILLARY ADMINISTRATOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 11, 1982.

Attorney(s) appearing for the Case

Isidore R. Tucker, for the petitioner.

Guy G. Lavignera, for the respondent.

PARKER, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $10,035.95 and an addition to the tax under section 6651(a)(1)1 of $2,508.99. The issues for decision are:

(1) Whether decedent was a citizen of the United States at the time of his death so that his estate is liable for U.S. estate tax;

(2) Whether the Estate Tax Treaty with Greece exempts from U.S. estate tax the estate of a...

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