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STAMOS v. COMMISSIONER

Docket Nos. 3096-77, 8574-77, 8299-78, 6238-79.

87 T.C. 1451 (1986)

THEODOROS STAMOS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 30, 1986.

Attorney(s) appearing for the Case

Arthur Richenthal, for the petitioner.

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

OPINION

SWIFT, Judge:

This matter is before the Court on petitioner's motion for summary judgment and respondent's motion for partial summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure. At issue are excise taxes and additions to tax in excess of $23 million.

The issues in this case arise out of the widely publicized and much litigated Estate of Mark Rothko (hereinafter sometimes referred to as the estate...

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