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ESTATE OF GREEN v. COMMISSIONER

Docket No. 17956-80.

82 T.C. 843 (1984)

ESTATE OF ETHEL P. GREEN, DECEASED, DAVID L. GREEN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 30, 1984.

Attorney(s) appearing for the Case

Joel E. Miller, for the petitioner.

Robert J. Alter, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $165.29 in petitioner's Federal estate tax. The sole issue for decision is whether the value of an annuity contract purchased by decedent's employer, a city school board, for the decedent's benefit is excludable from decedent's estate under section 2039(c)(3).1

This case was submitted fully stipulated pursuant to Rule 122. The stipulations of fact...

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