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ESTATE OF PATTERSON v. C.I.R.

No. 1199, Docket 84-4008.

736 F.2d 32 (1984)

ESTATE OF Mary King PATTERSON, James J. Patterson, Executor, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided May 30, 1984.

Attorney(s) appearing for the Case

John R. Schoemer, Jr., New York City (Roger E. Williams, Townley & Updike, New York City, of counsel), for appellant.

Elaine F. Ferris, Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Gary R. Allen, Tax Div., Dept. of Justice, Washington, D.C., of counsel), for appellee.

Before OAKES and VAN GRAAFEILAND, Circuit Judges, and BONSAL, District Judge.

PER CURIAM:

The Estate of Mary King Patterson, James J. Patterson, Executor (the Estate), appeals from a decision of the United States Tax Court, Irene Scott, Judge, which sustained the Tax Commissioner's determination of a deficiency of $729,624.76 in federal estate taxes. We affirm substantially for the reasons stated in the opinion of the Tax Court, T.C. Memo. 1983-381 (June 27, 1983...

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