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BIANCHI v. COMMISSIONER

Docket No. 4627-78.

44 T.C.M. 422 (1982)

T.C. Memo. 1982-389

Estate of Maria Bianchi, Peter Bianchi, Executor v. Commissioner.

United States Tax Court.

Filed July 13, 1982.

Attorney(s) appearing for the Case

L.G. von Schottenstein, 321 Bush St., San Francisco, Calif., for the petitioner. J. Michael Chitwood, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in Federal estate tax for the estate of Maria Bianchi, Peter Bianchi, executor, in the amount of $173,903. The issues for decision are as follows:

(1) Whether all or any part of two farm properties which decedent transferred in return for private annuities are includable in her gross estate under section 20361 because decedent retained...

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