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  5. 729 F.2d 496 (1984)
 

BERLIANT v. C. I. R.

Nos. 83-1413, 83-1414.

729 F.2d 496 (1984)

Phyllis BERLIANT, Transferee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Florence KRAFT, Transferee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 5, 1984.

Rehearing and Rehearing Denied April 4, 1984.

Attorney(s) appearing for the Case

Richard Kates, Chicago, Ill., for petitioners-appellants.

Thomas M. Preston, Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before CUMMINGS, Chief Judge, WOOD, Circuit Judge, and CAMPBELL, Senior District Judge.

Rehearing and Rehearing En Banc Denied April 4, 1984.

CUMMINGS, Chief Judge.

This is an appeal by Florence Berliant Kraft (Kraft) and Phyllis Berliant (Berliant) from a decision of the United States Tax Court finding Kraft, Berliant and Irene Berliant Magill1 liable for unpaid taxes of the estate of decedent Rae Berliant (Rae). Magill v. Commissioner, 51 TCM (P-H) ¶ 82,148 (filed March 24, 1982) (App. 1-53). Tax Court...

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