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ESTATE OF LEVY v. COMMISSIONER

Docket No. 5833-81.

46 T.C.M. 910 (1983)

T.C. Memo. 1983-453

Estate of Herbert Levy, Ilse Levy, Executrix v. Commissioner.

United States Tax Court.

Filed August 2, 1983.

Attorney(s) appearing for the Case

Donald A. Richards, for the petitioner. Richard J. Sapinski, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency of $4,492.84 in petitioner's Federal estate taxes. Due to concessions by petitioner, the sole issue remaining for decision is whether the value of a trust created by decedent's wife is includible in decedent's estate under section 2036.1

Findings of Fact

This case was fully stipulated under Rule 122.2...

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