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ESTATE OF DONALDSON v. COMMISSIONER

Docket No. 2227-77.

49 T.C.M. 564 (1985)

T.C. Memo. 1985-33

Estate of Jennie R. Donaldson, Deceased, William E. Murray, Leila M. Atwood and Perry M. Sample, Executors v. Commissioner.

United States Tax Court.

Filed January 16, 1985.

Attorney(s) appearing for the Case

William E. Murray, for the petitioner. Bradford A. Johnson, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

Respondent, in a statutory notice dated December 27, 1976, determined a deficiency of $13,796,689.72 in petitioner's Federal estate tax liability. Following concessions by the parties, the sole issue remaining for decision is the net value of property received by decedent Jennie R. Donaldson (hereinafter referred to as "Jennie") from the estate of her deceased husband Oliver S. Donaldson (hereinafter...

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