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ESTATE OF FULMER v. COMMISSIONER

Docket No. 14851-83.

83 T.C. 302 (1984)

ESTATE OF VERNIS FULMER, DECEASED, LOIS FULMER, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 30, 1984.

Attorney(s) appearing for the Case

Merle R. Flagg, for the petitioner.

William P. Hardeman, for the respondent.

OPINION

SIMPSON, Judge:

This matter is before us on the Commissioner's motion, which we shall treat as a motion for summary judgment under Rule 121, Tax Court Rules of Practice and Procedure.1 At the hearing on the motion, the parties agreed that there is no genuine issue as to any material fact and that a decision may be rendered by us as a matter of law pursuant to Rule 121,...

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