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ESTATE OF REIS v. COMMISSIONER

Docket Nos. 3095-77, 8466-78, 8775-77.

87 T.C. 1016 (1986)

ESTATE OF BERNARD J. REIS, DECEASED, REBECCA G. REIS, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 10, 1986.

Attorney(s) appearing for the Case

Arthur N. Greenberg, Sidney J. Machtinger, and Gary L. Kaplan, for the petitioners.

George W. Connelly, Jr., for the respondent.

OPINION

SWIFT, Judge:

This matter is before the Court on cross-motions for summary judgment. Each party alleges that if its or his respective motion for summary judgment is denied, factual issues will remain which preclude entry of summary judgment in favor of the other party. The excise tax and additions to tax in dispute herein exceed $21 million.

The issues in this case arise out of the widely...

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