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ESTATE OF ALDRICH v. COMMISSIONER

Docket No. 5553-81.

46 T.C.M. 1295 (1983)

T.C. Memo. 1983-543

Estate of Russell E. Aldrich, Deceased, Grace Marie Aldrich, Executrix v. Commissioner.

United States Tax Court.

Filed September 1, 1983.

Attorney(s) appearing for the Case

James E. Coombs, and Raymond M. Pezzo, 94 Market St., Poughkeepsie, N.Y., for the petitioner. Bradford A. Johnson, for the respondent.

Memorandum Opinion

STERRETT, Judge:

By notice of deficiency mailed to the petitioner on or about December 18, 1980, respondent determined a deficiency in petitioner's estate tax liability of $25,474.78. The issue for our determination is whether the decedent's gross estate as defined in section 2031, I.R.C. 1954, included the decedent's interest in a contingent legal fee arrangement for a case that was unsettled...

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