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ESTATE OF GARNER v. COMMISSIONER

Docket No. 16192-80.

44 T.C.M. 903 (1982)

T.C. Memo. 1982-481

Estate of Alfred A. Garner, Deceased, Waldo Garner, Administrator v. Commissioner.

United States Tax Court.

Filed August 23, 1982.

Attorney(s) appearing for the Case

Forrest Walpole, 194 North State St., Caro, Michigan, for the petitioner. Richard A. Witkowski, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in Federal estate tax of the estate of Alfred A. Garner, deceased, Waldo Garner, Administrator, in the amount of $104,900.56.

The sole issue for decision is whether all or any part of several farm properties which decedent transferred by gift more than 3 years before the date of his death are includable in his gross estate under section 2036,

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