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ESTATE OF DEWITT v. COMMISSIONER

Docket No. 35533-86.

54 T.C.M. 759 (1987)

T.C. Memo. 1987-502

Estate of Helen Ward DeWitt, deceased, John H. DeWitt and Albert P. Morelli, Executors v. Commissioner.

United States Tax Court.

Filed September 28, 1987.

Attorney(s) appearing for the Case

Albert R. Mugel, 800 Novstar Bldg., Buffalo, N.Y., for the petitioners. Edward D. Fickess, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

This matter is before the Court on petitioners' motion for partial summary judgement, filed June 9, 1987, pursuant to Rule 121.1 Respondent filed a response in opposition to petitioners' motion. Both petitioners and respondent submitted memoranda and accompanying affidavits in support of their positions.

By a notice of deficiency dated June 4, 1986, respondent determined a deficiency...

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