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BLACK v. COMMISSIONER

Docket No. 9967-80.

47 T.C.M. 1318 (1984)

T.C. Memo. 1984-136

Richard H. Black, deceased, Phyllis M. Black, Personal Representative v. Commissioner.

United States Tax Court.

Filed March 20, 1984.

Attorney(s) appearing for the Case

Stephen S. Case, 10331 Coggins Dr., Sun City, Ariz., for the petitioner. William A. Clarke and Dennis C. DeBerry, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:*

Respondent determined a Federal estate tax deficiency of $41,366.17. The issue for decision is whether more than one-half of the value of securities held in a revocable trust established by decedent and his wife, securities that had previously been owned by them as joint tenants with right of survivorship, is includable in decedent's gross estate under either section 2040...

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