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ESTATE OF CLEVELAND v. COMMISSIONER

Docket No. 15425-79.

45 T.C.M. 1403 (1983)

T.C. Memo. 1983-227

Estate of Mary Webb Cleveland, Deceased; First Alabama Bank of Tuscaloosa, N.A., A National Banking Association, Executor v. Commissioner.

United States Tax Court.

Filed April 25, 1983.

Attorney(s) appearing for the Case

J. William Lewis, 800 First National-Southern National Bldg., Birmingham, Ala., John C. Coggin III, and F. Gerald Burnett, for the petitioner. Robert W. West, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in the Federal estate tax of the estate of Mary Webb Cleveland, Deceased, First Alabama Bank of Tuscaloosa, N.A., executor, in the amount of $348,121.

Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision the following: (1) Whether decedent was the actual owner of assets held in the name of the...

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