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ESTATE OF EGGER v. COMMISSIONER

Docket No. 39777-86.

89 T.C. 726 (1987)

ESTATE OF LUIS G. EGGER, DECEASED, JAMES H. POWELL, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

Filed September 23, 1987.

Attorney(s) appearing for the Case

Herbert Hoover Chaice, for the petitioner.

Kevin C. Reilly, Louis B. Jack, and Vincent J. Juliano, for the respondent.

OPINION

Sterrett, Chief Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d), I.R.C. 1954 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180 et seq. The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

OPINION OF THE SPECIAL TRIAL...

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