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ESTATE OF FABRIC v. COMMISSIONER

Docket No. 17536-81.

83 T.C. 932 (1984)

ESTATE OF MOLLIE P. FABRIC, ELLIOT FABRIC, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 11, 1984.

Attorney(s) appearing for the Case

David M. Berman, Malcolm H. Neuwahl, and David A. Freedman, for the petitioners.

Lourdes M. DeSantis, for the respondent.

STERRETT, Judge:

By notice of deficiency dated April 13, 1981, respondent determined a deficiency of $457,902 in the Federal estate tax of the Estate of Mollie P. Fabric. After concessions, the issues before us are: (1) Whether the decedent entered into a valid annuity or retained a life estate in the transferred properties, and (2) if a valid annuity existed, whether adequate and full consideration was given.

FINDINGS OF FACT

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